Junk Plant Hope Creek: Really, No Part 21 Procedure On Site?

Update June 13

I guess my information was wrong. Now a non dependable source. Had to run it to ground to the best of my ability. You lose credibility during a operation like this.  

R1ALLEGATION RESOURCE <R1ALLEGATION.RESOURCE@nrc.gov>	3:14 PM (4 hours ago)
to me

Mr. Mulligan,

I am responding to your email dated June 6, 2017, regarding the Hope Creek Part 21 program.  I forwarded your questions and concerns to the NRC Region I branch responsible for oversight of Hope Creek.  We reviewed the PI&R team report that you referenced (IR 05000354/2015008), and talked to the Salem and Hope Creek resident inspectors regarding their knowledge of the Part 21 program.

You stated that the lack of a Part 21 procedure is contrary to 10 CFR Part 21.21, which requires, in part, that, “Each individual, corporation, partnership, dedicating entity, or other entity subject to the regulations in this part shall adopt appropriate procedures to… Evaluate deviations and failures to comply to identify… a reportable defect or failure to comply that could create a substantial safety hazard...”

The NRC Region I staff has determined that PSEG meets 10 CFR Part 21.21 through the implementation of three separate procedures:

·         LS-AA-115-1006, which evaluates incoming Part 21 reports;

·         LS-AA-120, which describes the process and expectations for issue identification; and

·         CC-AA-309-1012, which describes the process for conducting Part 21 Technical Evaluations.

While the Region I staff has concluded that the current guidance meets the requirements of 10 CFR Part 21.21, we continue to inspect Part 21 issues as they arise and monitor PSEG’s performance in this area.

Sincerely,

Nicole Warnek

Sr. Allegation Coordinator

Update June 11

Maybe Allegations wasn't keeping the inspections in the LOOP. Maybe the inspectors answered me off the cuff without thinking. They assumed the Site had a part 21 procedure, but never checked.   

Update June 7

I don't know why I didn't do this first. The Hope Creek NRC's admin assistant relayed from the inspectors saying they "do" have a part 21 procedure. But they are too busy to talk to me.

Maybe it is a new procedure?  


Update: The Allegation official was the team leader in the below chiller inspection. The licensee had a horrendous repeated problem with trying to solve this part 21 issue and failed to report this to the NRC. It would be a NRC automatic reflex response to check out the part 21 procedure or any other similar botched issue in the plant. I accused the team leader, now a Allegation official...they should have picked up the missing procedure, they didn't do their job. It looks to me like you were protecting PSEG by not violating them on the missing part 21 procedure. This is preliminary information. This is the strange NRC's response. I expected them to either say Hope Creek has a part 21 procedure or not. Bet you the lawyers were involved?

"I led the biennial Problem Identification and Resolution team inspection in my role as a qualified reactor inspector. It was not related to my current position in the Allegation/Enforcement team. 

Happy to talk more about the Part 21 observation documented in my inspection report. Note that it is 2.5 years old, and I am not aware of the current status of any Part 21 procedures." 

At first blush, I find it preposterous a US nuclear plant won't have a part 21 procedure. How many plants in the USA don't have a part 21 procedure? It implies that many required procedures at many plants are missing. I am now working closely with the NRC as we speak. 

Does this blurt from the inspection report indicate the missing Part 21 procedure...the missing and late reportability issue?

Regarding Part 21. PSEG has no part 21 procedure.

https://www.nrc.gov/docs/ML1508/ML15085A348.pdf

Temperature Switch Potential Part 21 Issue Notification (NOTF) 20626121 documented an October 2013 trip of the ‘A’ main control room chiller. PSEG performed an apparent cause evaluation (ACE) and determined that the trip was due to the bearing oil temperature switch momentarily pegging high. The ACE cited electromagnetic interference (EMI) as the most likely cause, and the switch was sent to a vendor for failure analysis. In an August 2014 report, the vendor confirmed EMI as a likely cause of the switch failure. The ACE included an action item (ACIT) to evaluate the switch for Part 21 reportability, if EMI was found to be the cause and was determined to be within the switch specifications. This ACIT was initially due in January 2015, but, at an MRC meeting attended by the inspection team in late January 2015, the due date was extended to June 2015. The inspectors noted that, if the issue were ultimately determined to warrant reporting under 10 CFR Part 21, the station would have 60 days from the time of discovery to submit the required Part 21 report.

The inspectors determined that Hope Creek has not taken timely action to determine whether the temperature switch EMI issue is reportable under the Part 21 process. As of the time of the inspection, it had been 16 months since the switch initially failed, and six months since the failure analysis report was received, and the station had not yet determined if the switch had operated within its design, or if the failure constituted a deviation or non-conformance subject to the Part 21 process. The inspectors determined the performance deficiency was minor, because the issue is most likely not required to be reported under 10 CFR 21. Specifically, the inspectors noted that the vendor’s failure analysis determined the switch was only subject to EMI at levels below those typically present in the nuclear power plant environment, and below the levels that NRC requires electrical components to be designed and tested to NRC Regulatory Guide 1.180, “Guidelines for Evaluating Electromagnetic and Radio-Frequency Interference in Safety-Related Instrumentation and Control Systems.” 

A NRC Allegations employee recently led the NRC team who inspected Hope Creek surrounding a Part 21 issues. They had other part 21 issues.

Why didn't the employees force PSEG to write the procedure. This indicates safety culture problems and intimidations...

General Provisions
§ 21.1 Purpose.

The regulations in this part establish procedures and requirements for implementation of section 206 of the Energy Reorganization Act of 1974. That section requires any individual director or responsible officer of a firm constructing, owning, operating or supplying the components of any facility or activity which is licensed or otherwise regulated pursuant to the Atomic Energy Act of 1954, as amended, or the Energy Reorganization Act of 1974, who obtains information reasonably indicating: (a) That the facility, activity or basic component supplied to such facility or activity fails to comply with the Atomic Energy Act of 1954, as amended, or any applicable rule, regulation, order, or license of the Commission relating to substantial safety hazards or (b) that the facility, activity, or basic component supplied to such facility or activity contains defects, which could create a substantial safety hazard, to immediately notify the Commission of such failure to comply or such defect, unless he has actual knowledge that the Commission has been adequately informed of such defect or failure to comply.

Junk Plant Grand Gulf-What a Absolute NRC Disgrace

Delay, Delay, Delay....

The NRC paper tiger...

Remember the abysmal capacity factor in the last two years, the four month shutdown over not following procedures and the recent slow start-up over unclear procedures.

No wonder the staff is so demoralized over a management philosophy such as what caused the below...

GRAND GULF NUCLEAR STATION – NRC TRIENNIAL FIRE PROTECTIONINSPECTION REPORT 05000416/2017008

Dear Mr. Larson:

On April 21, 2017, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Grand Gulf Nuclear Station and discussed the results of this inspection with you and other members of your staff.  The results of this inspection are documented in the enclosed report.

NRC-Identified and Self-Revealing Findings

 Cornerstone:  Mitigating Systems

• Green.  The team identified a non-cited violation of License Condition 2.C.(41) for failure to correct a condition adverse to fire protection in a timely manner.  Specifically, the licensee failed to complete evaluations of multiple spurious operations (MSO) concerns identified in 2011.  The licensee entered this finding into their corrective action program as Condition Report CR-GGN-2017-03996. 

The failure to correct a condition adverse to fire protection in a timely manner was a performance deficiency.  The performance deficiency was more than minor because it was associated with the protection against external events (fire) attribute of the Mitigating Systems cornerstone and it adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences.  Specifically, untimely resolution of these MSO actuations placed the facility at risk of being unable to safely shutdown the facility in response to a fire. 

The finding was screened in accordance with Inspection Manual Chapter (IMC) 0609, “Significance Determination Process,” Attachment 4, “Initial Characterization of Findings,” dated June 19, 2012.  Because the finding affected the ability to achieve and maintain post-fire safe shutdown, the team reviewed the finding using IMC 0609, Appendix F, Attachment 1, “Fire Protection Significance Determination Process Worksheet,” dated September 20, 2013.  The finding was screened as a Green finding of very low safety significance in accordance with Task 1.3, “Ability to Achieve Safe Shutdown,” Question A.  Although the licensee failed to completely evaluate the impact of MSOs that could potentially result in the loss of suppression pool inventory, the team determined that for all fire areas one division of the residual heat removal system and the supporting standby service water system remained available along with suppression pool level indication.  The team confirmed that suppression pool makeup for the standby service water system would remain available.  For the postulated control room fire that led to control room evacuation, a senior reactor analyst performed a Phase 3 evaluation to determine the risk significance of this finding.  The senior reactor analyst determined this finding was of very low safety significance.  The finding had a cross-cutting aspect in the Conservative Bias component of the Human Performance area because the licensee failed to use decision making-practices that emphasize prudent choices over those that are simply allowable.  Specifically, the licensee reclassified a condition report to be non-adverse allowing resolution to be given a lower priority prior to completing the evaluations required to provide a technical basis for that decision [H.14].  (Section 1R05.01.b)

• Green.  The team identified a Green non-cited violation of Technical Specification 5.4.1.a for the failure to implement and maintain adequate written procedures covering a fire in the control room.  Specifically, the licensee failed to maintain an alternative shutdown procedure that ensured operators could safely shut down the plant under all postulated fire scenarios within the time limits established by the thermal hydraulic analysis.  The licensee entered this finding into their corrective action program as Condition Report CR-GGN-2017-04011.  As an immediate compensatory measure, the license issued Standing Order 17-0010 to provide operators additional guidance.  

The failure to implement and maintain adequate written procedures covering timed operator actions during a fire in the control room was a performance deficiency.  The performance deficiency was more than minor because it was associated with the procedure quality attribute of the Mitigating Systems Cornerstone and it adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences.  Specifically, the alternative shutdown procedure failed to ensure operators could safely shut down the plant under all postulated fire scenarios within the time limits established by the thermal hydraulic analysis.  The team evaluated this finding using Inspection Manual Chapter 0609, Appendix F, “Fire Protection Significance Determination Process,” dated September 20, 2013, because it affected the ability to reach and maintain safe shutdown conditions in case of a fire.  A senior reactor analyst performed a Phase 3 evaluation to determine the risk significance of this finding since it involved a postulated control room fire that led to control room evacuation.  The senior reactor analyst determined this finding was of very low safety significance.  

The finding did not have a cross-cutting aspect since it was not indicative of present performance in that the performance deficiency occurred more than 3 years ago.  (Section 1R05.05.b.1)

• Green.  The team identified a Green non-cited violation of License Condition 2.C.(41) for the failure to implement and maintain in effect all provisions of the approved fire protection program.  Specifically, the licensee failed to adequately isolate control circuits for safe shutdown equipment to ensure independence from the effects of a fire in the control room.  The licensee entered this finding into their corrective action program as Condition Report CR-GGN-2017-04028.  As an immediate compensatory measure, the licensee issued Standing Order 17-0010 to provide operators additional guidance. 

The failure to adequately isolate control circuits for safe shutdown equipment from the effects of a control room fire was a performance deficiency.  The performance deficiency was more than minor because it was associated with the protection against external events (fire) attribute of the Mitigating Systems Cornerstone and it adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences.  Specifically, the spurious actuation of safety relief valves would adversely affect the safe shutdown equipment relied upon to achieve and maintain safe shutdown conditions.  The team evaluated this finding using Inspection Manual Chapter 0609, Appendix F, “Fire Protection Significance Determination Process,” dated September 20, 2013, because it affected the ability to reach and maintain safe shutdown conditions in case of a fire.  A senior reactor analyst performed a Phase 3 evaluation to determine the risk significance of this finding since it involved a postulated control room fire that led to control room evacuation.  The senior reactor analyst determined this finding was of very low safety significance.  

The finding did not have a cross-cutting aspect since it was not indicative of present performance in that the performance deficiency occurred more than 3 years ago.  (Section 1R05.05.b.2)

• Green.  The team identified a Green non-cited violation of Technical Specification 5.4.1.a for the failure to maintain adequate written procedures covering a fire in the control room.  Specifically, the licensee failed to ensure that all steps in Procedure 05-1-02-II-1, “Shutdown from the Remote Shutdown Panel,” could be performed as written.  Specifically, the licensee’s procedure did not provide specific guidance to the control room staff on how to actuate the low pressure core spray pump breaker lockout relay.  The licensee initiated Condition Report CR-GGN-2017-03368 to address the deficiency and immediately implemented Standing Order 17-0009, which provides specific guidance to the control room staff on how to actuate the low pressure core spray pump breaker lockout relay.

The failure to provide a procedure that operators understood to implement the requirements of the approved fire protection program for a fire in the control room was a performance deficiency.  The performance deficiency was more than minor because it was associated with the procedure quality attribute of the Mitigating Systems Cornerstone and it adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences.  Specifically, the alternative shutdown procedure failed to ensure operators could safely shut down the plant during a control room fire causing circuit faults.  The team evaluated this finding using Inspection Manual Chapter 0609, Appendix F, “Fire Protection Significance Determination Process,” dated September 20, 2013, because it affected the ability to reach and maintain safe shutdown conditions in case of a fire.  A senior reactor analyst performed a Phase 3 evaluation to determine the risk significance of this finding since it involved a postulated control room fire that led to control room evacuation.  The Senior Reactor Analyst determined this finding was of very low safety significance.  

The finding did not have a cross-cutting aspect since it was not indicative of present performance in that the performance deficiency occurred more than 3 years ago.  (Section 1R05.05.b.3)

Junk Plant Millstone-Dominion is a Gonner!

You can't tell this hasn't changed the mentality of all the employees. Would you do sneaky things if your job was on the line? You can't convince me they haven't already been throttling funding to the huge site. 

I told you, the pre 2008 utility business model with far flung plants from your base state is dead. Its obsolete in the new fracking era.

As time has gone on with this legislation, Dominion have gotten more strident with the "we are shutting down" if we aren't getting corporate welfare. It is as if they see as the storm is approaching the plant, it is massively strengthening.  

Millstone Owner To Reconsider Keeping Nuclear Plant Open If Legislation Fails

Dan Weekley, vice president of corporate affairs at Dominion, discusses the pending legislation related to Millstone. (Stephen Singer)

Dan Weekley, vice president of corporate affairs at Dominion, discusses the pending legislation related to Millstone. (Stephen Singer)

Stephen Singer Contact Reporter

The corporate owner of Millstone said Monday it will reconsider keeping the Waterford nuclear plant open or making other unspecified changes if the legislature fails to back a measure broadening its access to electricity markets.

With a Wednesday deadline looming for the end of the 2017 session of the General Assembly, lawmakers have yet to debate legislation in the Senate or House that Millstone parent company, Dominion Energy Inc., has lobbied hard to pass. A similar measure failed at the end of last year's legislative session.

"Regrettably, if Connecticut chooses not to act, we will begin a strategic reassessment of our plans for Millstone Power Station," Dominion spokesman Kevin Hennessy said.

The Richmond, Va.-based energy company alluded to Connecticut's loss of the headquarters of General Electric Co., which left Fairfield for Boston, and the impending departure of the Hartford headquarters of Aetna Inc., which announced last week it's negotiating with other states to relocate.

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"It would be surprising and a missed opportunity for Connecticut not to reduce the highest electric rates in the continental United States, meet its long-term carbon goals and ensure the sustainability of a major employer this year given recent events," Hennessy said.

"We remain committed to finding a long-term solution that benefits the people of Connecticut, but we also must be fiscally responsible with our investments," he said.

The legislature's energy and technology committee approved the legislation in March. But several lawmakers criticized Dominion for refusing to prove it needs special attention from the legislature by opening its books.

Dominion said it should not be held to a standard different from other companies that benefit from legislation.

The Millstone legislation has become the most contentious energy bill in the legislature this year. A coalition of non-nuclear power generators, environmentalists and consumer activists lobbied against the measure, accusing Dominion of seeking a "corporate payout."

Dominion countered by saying the bill authorizes it to bid for state power contracts on an equal footing with other generators. Millstone would be able to reduce prices by selling directly to energy retailers rather than on hedge fund markets that create no value for consumers and instead drive up prices, Dominion says.

The rise of abundant and relatively cheap natural gas has put plants like Millstone at a severe economic disadvantage. Several plants in the U.S. have closed, with Exelon announcing last week it will shut its Three Mile Island plant in 2019 unless Pennsylvania state officials include nuclear power in alternative-energy goals.

House Speaker Joe Aresimowicz said Monday that legislation favored by Dominion "doesn't look good right now, but there's three days left and anything can happen."

He said he's not convinced that Millstone would be irreparably harmed by the legislature's failure to act. "I don't know that it's a pressing problem if we don't act in the next six months," he said.

House Majority Leader Matt Ritter said Monday a shutdown of Millstone is not imminent.

"They're not closing tomorrow. They're not closing next year," the Hartford Democrat said.

Andy Pusateri, an analyst with Edward Jones, said Dominion ultimately wants to keep Millstone open and suggested it raised the possibility of shutting the plant as perhaps a "negotiating tactic."

"At the end of day if they don't see them as cost-effective or the legislature doesn't do what it takes to make them profitable, they'll retire them," he said.

Thedilemma faced by policymakers and the industry is that gas prices are projected to stay low, making it hard for nuclear plants to compete, Pusateri said. But as natural gas prices climb, nuclear power may be back in demand, he said.

The stakes are high for the state's economy, particularly in southeast Connecticut where the Millstone nuclear plant operates. A study commissioned in October by Dominion said Millstone generates $1.47 billion in annual economic impact and employs more than 1,000 workers. It accounts for 59 percent of the power consumed by Connecticut utility customers, Dominion said.

Three nuclear plants operate in New England: Millstone, Pilgrim in Massachusetts and Seabrook in New Hampshire. Nuclear power accounted for 30 percent of energy generated in the region in 2015, down from 34 percent the previous year, according to ISO-New England.

Vermont Yankee retired in 2014 and Pilgrim is set to close in 2019.

A spokeswoman for ISO-New England would not comment on what the region's grid operator would do if Millstone shuts.

Rep. Lonnie Reed, the House chairwoman of the energy and technology committee, said failure to pass the bill could lead to another hit to Connecticut's economy...

Senior NRC Employees Unable to Control Their Monstrous Bureaucracy

Mike Mulligan <steamshovel2002@gmail.com>	11:46 AM (1 hour ago)
to NRC

Mrs. Warnek,

We got to straighten out our communication channels. So your last response came to me through my yahoo e-mail address. Yet, you know my yahoo e-mail won't  get through the NRC's virus protection system. I have to answer you through my goggle e-mail account. It is clumsy as hell. It is pretty neat I predicted last night it would occur again. It's not like I haven't tried to address this before with the NRC. I have had to get the NRC Chairman involved in the past to try and fix this. I am sure if you do a search in your system you will pick up email to the chairman and all responses back a forth. Yahoo is in the top three email platforms in the USA. It is used by millions of people. Why do we have to go over this over and over again. Why can't it be fixed the first time. I find it highly disrespectful as a member of the public...how the agency treats us. I have 100% confidence a NRC email will get through my virus protection software. I have 100% confidence my e-mail through my yahoo account "will not" get through the NRC's virus protection system. I thoroughly documented my NRC yahoo Daemon- NRC virus protection software rejection exploits on my blog. Just google The Popperville Town Hall, yahoo Daemon. 

I am not saying anything of this issue is involved with you. My gripe is with the NRC system in not fixing the problem the fist time. The NRC's inability to not be able to detect and correct it on their own. The inability of the agency to be self directed. 

The NRC is going to have to come up with policy in how the public uses yahoo e-mail sent to the Allegation department or anywhere else in your system, or fix your software. I know your IT system is extraordinarily complex and involves many contractors. 

I am not saying the NRC is rejecting my particular emails. Your virus software just thinks my e-mail is garden verity yahoo spam. Yahoo massive level spam overwhelms many organizational IT systems throughout the nation.  

 

http://steamshovel2002.blogspot.com/2012/12/nrc-mailer-daemon-message.html

NRC MAILER-DAEMON message?

Millstone: Connecticut Said Drop Dead To The Financially Starved Facility

This was a bad week for the nuke industry. TMI is said to shutdown in 2019. Pilgrim had its last shutdown. Trump backed out of the Paris climate agreement, the governmental welfare gravy train for the utilities is dead.

Remember there has been a drastic collapse in electric prices in the last three or four years. This recent increase in prices is just a temporary blip on the continuing collapse.  

Wholesale Electricity Prices and Demand in New England

Dominion is a out of state company. If it was a Connecticut utility, would the legislators be more sympatric to Millstone. Having far flung electric plants "states" away from the parent company is a 1990s and non fracking business model. The times of increasing cheap natural gas has severely disrupted this model. What, Millstone/Dominion is a Richmond Virginia based utility and Seabrook/Nextera is a Juno Florida based utility. I think safety is highest when the plants are locally controlled. Why has all the nuke plants in the New England controlled by southern foreigners?      

In the face of Trumpism, which way has the public approval rate turned in the last year and in the future? I think the approval rate is heading for a drastic turn to worst. The public is beginning to think the nuclear industry is a gasping dinosaur.  I also think the greater public will scapegoat the nuclear industry based on the floundering Trump administration. You can't trust anything government, why should the nuclear industry even be alive.

I wish Dominion would spend their millions of political monies on upgrading equipment and training than buying drinks for the politicians.   

Dominion Energy loses legislative fight over Millstone pricing

By: Mark Pazniokas | June 3, 2017

A long, intense and expensive lobbying campaign by Dominion Energy has failed to find the votes in the Connecticut General Assembly for legislation intended to improve the profitability of its Millstone Nuclear Power Station by changing the rules for procuring electricity.

“It’s dead. It’s a toxic brand now, literally radioactive,” Rep. Lonnie Reed, D-Branford, the co-chair of the Energy and Technology Committee. “Let’s let it go and figure out a new way.”

Dominion said it was seeking changes that would lower electric rates and stabilize profits generated by the state’s only nuclear-power plant, the source of nearly half of Connecticut’s electricity and most of its carbon-free energy. Opponents say the bill would cost ratepayers and produce a windfall for the plant’s owner, Dominion.

In interviews Friday night and Saturday, key legislators told CT Mirror that a Senate bill sought by Dominion over the opposition of environmentalists, consumer groups, other energy producers and the utility Eversource cannot go forward, unless it is reduced to a call for a study.

Senate Majority Leader Bob Duff, D-Norwalk, and Sen. Gary Winfield, D-New Haven, another energy co-chair, said in interviews Friday night that a concept passed unanimously by the Senate a year ago, only to be blocked in the House, no longer has even a simple majority.

Only Sen. Paul Formica, R-East Lyme, an energy co-chair whose district includes Millstone, declined to concede defeat, interrupting a somber conversation with Winfield to say only, “The session’s been a struggle.”

But a small army of Dominion officials and lobbyists, a visible presence at the State Capitol on Friday, had decamped on Saturday, when only the House was in session.

Kevin R. Hennessy, a Dominion government affairs executive, said failure to pass the bill would be a loss for Connecticut.

“The status quo, which our opponents champion, is not working for Connecticut,” he said. “It would be surprising and a missed opportunity for Connecticut not to reduce the highest electric rates in the continental United States, meet its long-term carbon goals and ensure the sustainability of a major employer this year given the events of this week.”

In the year since the Senate passed the original bill, Dominion’s opponents have mounted a lobbying and advertising campaign that matched or even exceeded the effort by Dominion.

“That full-on bill is not going to happen. Anything more than a study is not going to happen,” Reed said. “Dominion doesn’t want a watered-down bill. They want to play hardball in the post-session atmosphere.”

Low natural gas prices have driven down the daily auctions that set the wholesale price of electricity. Under the legislation, Dominion would have been able to use long-term contracts to lock in prices for up to half its Millstone output as a hedge against daily market volatility.

Dominion had been insulating itself from the highs and lows of the spot market by selling energy through a series of futures contracts that run for three years. But the daily market is so volatile that the futures market has faltered.

The bill would have allowed power from Millstone to compete in the market with biomass and trash-to-energy plants if the Department of Energy and Environmental Protection decided it was in the best interest of consumers.

Dominion has neither threatened nor reassured Connecticut on the status of Millstone in an era when electricity generated by cheap natural gas has depressed the electric markets, accelerating the closure of nuclear plants that still have years of service left on their operating licenses.

AARP, a grass-roots advocacy group for retirees that has grown into a broader consumer lobby, opposed the legislation unless Dominion agreed to open its books and demonstrate that Millstone was on the verge of unprofitability. Without providing details on Millstone’s finances, Dominion instead pointed to nuclear plants in Vermont, New York, Massachusetts and elsewhere that have closed or are slated to close.

Analysts that track the power industry did not help Dominion’s cause, noting that the company’s public filings and other information showed it would be profitable for at least the near future. UBS, for example, told investors earlier this year: “We continue to note that Millstone appears poised to drive positive cash flow through the forecast period. This would appear to reduce the merit of a legislative deal in CT.”

Risk Informed Regulations: A Undecipherable Language Even to Sophisticated Professionals

What about NRC's focus to make their documents understandable to the common person. So here the NRC and the industry are jockeying for organizational advantage.  

These guys have invented a language nobody can understand. Probably only a handful of people in the USA can understand. They are splitting a hair on  a knat's ass to gain plant capacity factor with the possibility of both sides of the identical redundant component being degraded and broken at the same time.

They are turning engineering uncertainty into certainty. This is all special interest advantage dressed up as science, engineering and proof. They has been no actual testing of the system with this. It all guesswork.

Right, this is how corruption in industry is played out in our rotten political system. It goes on in all sides Dems and Reps. They jack up the complexity of the undecipherable regulation language so nobody on the outside can understand what is going on. In the stew of this self imposed language complexity, they get to choose what fragment of regulation framework the use for specific issue. It is similar to having no regulations at all and going on a whim.  They give you the impression engineering stature based on science and facts...but it is all money greasing mindless deregulation for profit. They are chasing their tails finding money can be made off of it.  

Right, and who profits the most from this. Its the politicians. It forces the politician to step in and settling these weasel words disputes without them even having a basic understanding how a nuke plant works. The genesis of all the too complex regulations and more knat's ass language hair splitting over regulation wording is money and stature to the politicians.

Even our common language is too imprecise, not complex enough, the penchant of humans to have different definitions for a word...to express the actual system hidden under the veil. There is a huge gap of knowledge of what we say we understand the system and what is the real system under the bullshit and money!!!

 Description of Common Cause Failure Treatment in the TS Risk Informed Completion
Time (RICT) Program
The NRC proposed the TS Section 5.5 RICT Program be modified to address common cause
failure (CCF) as follows:
[d]. If a high degree of confidence cannot be established that there is no common cause
failure that could affect the redundant components, the RICT shall account for the
increased possibility of common cause failure. Accounting for the increased possibility of
common cause failure shall be accomplished by one of the two methods below. If one of
the two methods below is not used, the TS front stop shall not be exceeded.
• The RICT calculation shall be adjusted to numerically account for the increased
possibility of CCF, in accordance with RG 1.177, as specified in Section A-1.3.2.1 of
Appendix A of the RG. That is, when a component fails, the CCF probability for the
remaining redundant components shall be increased to represent the conditional
failure probability due to CCF of these components, in order to account for the
possibility that the first failure was caused by a CCF mechanism.
OR
• Prior to exceeding the front stop, RMAs shall be implemented. These RMAs
shall not already be credited in the RICT calculation, and shall target the success of
redundant and/or diverse SSCs that perform the function(s) of the failed SSC, and, if
possible, reduce the frequency of initiating events that call upon the function(s)
performed by the failed SSC. Documentation of the RMAs shall be available for
NRC review.
The industry proposes the following wording:
[d]. If the extent of condition evaluation for inoperable structures, systems, or components
(SSCs) is not complete, the RICT shall account for the increased possibility of common
cause failure (CCF) by either:
1. Numerically accounting for the increased possibility of CCF in the RICT calculation;
or
2. Prior to exceeding the Completion Time, Risk Management Actions (RMAs) [not
already credited in the RICT calculation] shall be implemented that support redundant
or diverse SSCs that perform the function(s) of the inoperable SSCs, or reduce the
frequency of initiating events that challenge the function(s) performed by the
inoperable SSCs.
Discussion of Differences
1. The format is revised to be consistent with the ISTS and the Writer's Guide, such as using
numbers instead of bullets and the appropriate format of the logical connector "or." See
TS Program 5.5.1 for an example.
Page 2 5/31/2017
2. (Paragraph d) The proposed term "high degree of confidence" has no objective measure
and will likely lead to inspection issues. One individual's high degree of confidence may
not align with another's. Instead, the industry proposes the objective measure of
completion of an extent of condition evaluation. If such an evaluation is complete, a
licensee and the NRC staff can consider common cause failure to be assessed. If not,
additional margin should be included in the RICT calculation.
3. (Paragraph d) The staff and industry proposals state that the increased possibility of a
CCF shall be accomplished by using one of two methods. The staff proposal then states
that if one of the two methods isn't used, a RICT can't be calculated (i.e., the front stop
cannot be exceeded). This statement is unnecessary. If one of the two methods must be
used and one is not used, a RICT can't be used.
4. (First bullet point) A TS Administrative Control Program description provides the highlevel
requirements for a licensee-controlled program that implements the requirements.
Note the TS RIC program introduction states, "The program shall include the following."
The TS program should include the requirements and constraints on the licensee's
program, but not every detail. The industry proposal simplifies the staff proposal in
several ways:
a. It is sufficient to state that the increased possibility of a CCF must be accounted
for numerically. In their review of licensee's implementation of TSTF-505, the
NRC may review the method used to numerically account for an increased
possibility of CCF. Methods other than that described in RG 1.177 may be
acceptable.
b. The following explanatory statement is removed, "That is, when a component
fails, the CCF probability for the remaining redundant components shall be
increased to represent the conditional failure probability due to CCF of these
components, in order to account for the possibility that the first failure was caused
by a CCF mechanism." Licensees understand the purpose of numerically
accounting for an increased possibility of common cause failure and this type of
explanation is not necessary or found in other TS Administrative Controls.
c. The reference to Regulatory Guide (RG) 1.177 is removed. Regulatory Guides
are not intended to be requirements. As stated on the front page of RG 1.177,
"Regulatory guides are not substitutes for regulations, and compliance with them
is not required. Methods and solutions that differ from those set forth in
regulatory guides will be deemed acceptable if they provide a basis for the
findings required for the issuance or continuance of a permit or license by the
Commission." As stated previously, the NRC staff may review the methods for
accounting for CCG as part of their review of the licensee's amendment request.
Page 3 5/31/2017
5. (Second bullet point) The term "front stop," while used in NEI 06-09, is not defined and
does not appear in the TS or Bases. Its use should be avoided in the TS. The paragraph is
revised to state "Prior to exceeding the Completion Time," which is equivalent.
6. (Second bullet point) The requirement, "These RMAs shall not already be credited in the
RICT calculation," is eliminated. At most sites, there will be proceduralized RMAs in
place for many situations. The PRA may credit some or all of these actions, but the
benefit from identifying an activity as an RMA is that it is performed, it emphasizes to
the plant operator its importance, and the RMA becomes a focus of the control room
while the RICT is in effect. For example, a plant’s protective actions may include
protecting the redundant (as opposed to diverse) train and by using a zero-maintenance
model some credit may be in the RICT calculation for this action. However, other
RMAs, such a stopping work in the switchyard or limiting transient combustibles near the
redundant train, reduce overall plant risk and are not specifically credited in the RICT
calculation. Even if there are no additional unique RMAs beyond those credited in the
PRA model, this increased focus enhances plant safety.
7. (Second bullet point) The proposed term "target the success of redundant and/or diverse
SSCs" is undefined and may be misinterpreted by licensees and NRC inspection staff.
The phrase "support the redundant or diverse SSCs" is more typical wording. Also, the
term "and/or" is avoided in the TS (See the Writer's Guide, section 3.1.1.h). A logical
"or" serves the same purpose as "or" is not exclusive.
8. (Second bullet point) The term "if possible" is typically not used in TS as the TS
represent legal requirements. Instead of stating, "and, if possible, reduce the frequency
of," the conjunction was rewritten as "or reduce the frequency of…". As stated
previously, a logical "or" is not exclusive and one or both actions may be taken.
9. (Second bullet point) The term "failed SSC" was revised "inoperable SSC" to be
consistent with TS terminology and the introductory paragraph d.
10. (Second bullet point) The statement "Documentation of the RMAs shall be available for
NRC review," is redundant and is eliminated. The TS program requires following NEI
06-09. Section 2.3.2, "Documentation," of NEI 06-09, step 6, states, "Relative to
extended CTs beyond the front-stop CT, the following shall be documented: … 6.5. Risk
management actions implemented." This requirement is reiterated in Section 3.1 of the
NRC's SE states (page 8), under "Documentation," which states: "Each entry into the
RMTS is required to be properly documented to permit proper review and oversight to
determine compliance with the TS requirements. The minimum requirements include: …
RMAs including compensatory actions implemented."

Disgruntled Employee Terrorism Event Coming To a Nuclear Plant Near You?

We are torturing plant employees with rumors and actual plant closing. The industry condition is pretty bleak...these are going to be "the good old days" in a few years. We are setting our selves up for a internal terrorism event at a plant. A weak and deranged person is going to go berserk at a plant. The example would be a person with a knife or some weapon would step into the control room, then stab and kill employees there. He would barricade the doors...create a prolonged incident. It might me two or more people to act together to make a point. Something like a meeting or cafeteria , stab and kill lots of people. Bring in large quantities of undetectable explosives to damage the plant. Meltdown the plant to get even with the public for destroying his family and career.

Last time I spoke like this I had two FBI agents wanting to speak to me "before the end of daylight today".

May 31, 2017

Exelon: Still Time for Pennsylvania to Help Three Mile Island

FREE TRIAL

From Energy and Climate Report

Energy and Climate Report provides current, thorough coverage of clean energy, efficiency, and climate change legislation, regulation, policy, legal developments, and trends in the U.S. and...

By Rebecca Kern
Pennsylvania’s legislature still has time to help keep Exelon Corp.'s financially struggling Three Mile Island nuclear plant operating, Exelon’s Joseph Dominguez told Bloomberg BNA.
“We’re continuing the discussion with policymakers that we really began six or seven months ago: talking about the value proposition of nuclear, both from an environmental standpoint, as well as from fuel diversity and grid resilience standpoint,” Dominguez, Exelon’s vice president of governmental and regulatory affairs and public policy, told Bloomberg BNA May 31.
Exelon announced May 30 that it plans to prematurely close Three Mile Island by Sept. 30, 2019, due to financial losses at the plant from low wholesale power prices tied to the natural gas shale boom. In a statement announcing those plans, the company identified some potential policies that could keep the plant viable, including amendments to the state’s Alternative Energy Portfolio Standard and the creation of a zero-emissions credit program.
“We’ll see if there’s interest among policymakers to do the things that Illinois and New York were able to do,” Dominguez said. “We still have some time to have this discussion, but there is a sense of urgency in terms of starting to introduce policymakers to the subject.”
Last year, the Illinois Legislature approved a $235 million-a-year lifeline for Exelon’s Quad Cities and Clinton reactors after the company announced they would close. Also, New York’s Public Service Commission’s Clean Energy Standard—passed last summer—will issue credits for zero-emitting resources, such as nuclear plants, starting this June. Both those policy changes have triggered lawsuits and complaints to the Federal Energy Regulatory Commission, which has been without a quorum since February.

Junk Plant TMI Shutting Down Perminantly

What if this was a two plant facility? Did the meltdown really cause this shutdown? If it was a two plant facility, would it be more profitable? Would it have survived another few years? 

Exelon Announces Three Mile Island Nuclear Plant to Close in 2019

05/30/2017 | Aaron Larson

Exelon Corp. said it plans to retire the Three Mile Island (TMI) nuclear power plant around September 30, 2019, unless policy reforms are enacted in Pennsylvania.
The company used a similar ploy in Illinois to pressure lawmakers into passing the state’s Future Energy Jobs bill, which provides subsidies for nuclear power plants. In that case, Exelon announced the closure of the Clinton and Quad Cities stations, only to reverse the decision once the legislation received the necessary support.
TMI has been in jeopardy for some time. Last year, TMI failed to clear PJM’s 2019–2020 capacity auction. At the time, Exelon CEO Chris Crane said, “The capacity market alone can’t preserve zero-carbon emitting nuclear plants that are facing the lowest wholesale energy prices in 15 years.”
This year, PJM’s prices were even lower. Last week the regional transmission organization announced a 2020–2021 base residual auction price of $76.53/MW-day for most resources in its footprint. Both TMI and Quad Cities failed to clear the PJM auction.
“Today is a difficult day, not just for the 675 talented men and women who have dedicated themselves to operating Three Mile Island safely and reliably every day, but also for their families, the communities and customers who depend on this plant to produce clean energy and support local jobs,” Crane said in a press release.
Exelon said it is taking the first steps to shut down the plant. Items include sending PJM a deactivation notice and making permanent shutdown notifications to the Nuclear Regulatory Commission within 30 days, terminating capital investment projects needed for long-term operation of the plant, and canceling 2019 fuel purchases and outage planning.
One solution the company suggested was amending Pennsylvania’s Alternative Energy Portfolio Standard to include nuclear power. According to Exelon, nuclear power provides 93% of the state’s emissions-free electricity and avoids 37 million tons of carbon emissions, but its zero-emission attributes are not properly rewarded. Another option would be to establish a zero-emissions credit program, similar to the approach implemented in Illinois and New York.
“Like New York and Illinois before it, the Commonwealth has an opportunity to take a leadership role by implementing a policy solution to preserve its nuclear energy facilities and the clean, reliable energy and good-paying jobs they provide. We are committed to working with all stakeholders to secure Pennsylvania’s energy future, and will do all we can to support the community, the employees and their families during this difficult period,” Crane added.
The Illinois and New York subsidies are being contested, however. A group of generators filed suit in federal court last October to block the New York incentive program. The plaintiffs argue that the plan interferes with wholesale power prices in violation of the Federal Energy Regulatory Commission’s authority over interstate power sales.
In mid-February, the Electric Power Supply Association, Dynegy, Eastern Generation, NRG Energy, and Calpine Corp. filed a federal lawsuit against the State of Illinois, challenging its nuclear subsidies too. Monitoring Analytics—PJM’s independent market monitor—filed a motion with the U.S. District Court for the Northern District of Illinois about a month later to intervene as a plaintiff in the lawsuit as well.
If the subsidies were to be overturned in either case, it would be a huge loss for Exelon and could put at least a few nuclear plants back at risk for early retirement.

Junk Plant Hope Creek/Salem In Serous Decline and NRC Allegation

It sounds like they think they don't have enough information to make a probe. I know Allegations has been asking questions to the inspectors. I ask the NRC to scrub the SRVs for information...

So I have raised the temperature? 
What next???

We know this facility is under grave financial pressure and blackmailing the community with trying to keep the plant operating. 

To Michael Mulligan

CC R1ALLEGATION RESOURCE 

May 30 at 1:26 PM

Hi Mr. Mulligan, I have copied and pasted the text below.

 

Sincerely,

 

Nicole Warnek

Sr. Allegation Coordinator

610-337-5222 (Safety Hotline)

800-432-1156 x5222 (Toll Free)

 

 

Mike Mulligan                                                                                              RI-2017-A-0028

steamshovel2002@yahoo.com 

 

Subject:  Concerns You Raised to the NRC Regarding Hope Creek

 

Dear Mr. Mulligan:

 

This letter refers to your emails to the NRC Allegation email account on May 2 and 3, 2017, and telephone conversations with NRC staff on May 3, 4, and 12, 2017.  Based on these emails and conversations, we have identified three concerns under NRC regulatory jurisdiction related to safety relief valves at Hope Creek.  Enclosure 1 to this letter documents our understanding of your concerns.  If the descriptions of your concerns are not accurate, please contact me as soon as possible so they can be properly characterized prior to the completion of our review.  The NRC normally completes our review of technical matters within six months, although complex issues may take longer.

 

Our initial review of the information you provided determined that we would need additional details from you in order to perform an effective review of your concerns.  The information we are requesting is detailed in Enclosure 1.  If you have any such details to provide, please contact me within 10 days of the date of this letter.  If no additional information is provided we will attempt to evaluate your concerns to the extent possible based on the limited specifics. 

 

In accordance with our identity protection policy, the NRC intends to take all reasonable measures to not disclose your identity outside the agency, and only provide your identity to NRC staff members with a need to know.  For additional information on the NRC’s process for reviewing nuclear safety concerns, please refer to our brochure entitled "Reporting Safety Concerns to the NRC," which can be viewed on the NRC webpage at http://www.nrc.gov/reading-rm/doc-collections/nuregs/brochures/br0240/.  This brochure includes an important discussion of the identity protection provided by the NRC as well as the circumstances that limit the NRC's ability to protect an alleger's identity. 

 

Thank you for raising these concerns.  Should you have any additional questions, or if the NRC can be of further assistance in this matter, please call this office toll-free via the NRC Region I Safety Hotline at 1-800-432-1156, ext. 5222, between 7:30 a.m. and 4:15 p.m. EST, Monday through Friday, or contact me in writing at 2100 Renaissance Blvd, Suite 100, King of Prussia, PA 19406.    

 

Sincerely, 

 

Nicole S. Warnek

Senior Allegation Coordinator

 

Concern 1:

 

You asserted that there are commercial grade dedication problems concerning the safety relief valves (SRVs) at Hope Creek.

 

Concern 2:

 

You asserted that there are Part 21 problems with the SRVs at Hope Creek.

 

Concern 3:

 

You asserted that the SRVs at Hope Creek are in worse shape than the NRC knows. 

 

Partial Response to Concerns 1, 2, and 3:

 

As noted in the cover letter, we are requesting additional information from you in order to perform an effective review of your concerns.  Specifically, please provide us with additional details regarding the commercial grade dedication and Part 21 issues impacting the SRVs at Hope Creek, and any other details you have regarding Concern 3.  Such information would help us focus our review effort and ensure a thorough review of your concerns.