Grand Gulf: Most Explosive NRC High Official's 2.206 I Have Ever Seen

update March 7

Grand Gulf 2.206

Mike Mulligan <steamshovel2002@gmail.com>	10:32 AM (1 minute ago)
to Troy

Mr. Pruett,

I am a nuclear safety advocate. Here is my blog: http://steamshovel2002.blogspot.com/ and http://steamshovel2002.blogspot.com/2019/02/grand-gulf-most-explosive-nrc-high.html.

You are welcome to publish anything nuclear related on my blog. We can work out the details. I spend a lot of time on LinkedIn. 

I have been watching Grand Gulf and Entergy for years now. I call Entergy a outlaw corporation. It has just been unbelievable what the NRC has allowed at GG from my experience.

A few friends have been talking about your petition. You have no chance of effecting change within the NRC. You know that. I believe you need protection from the NRC. The Wall Street Journal wants to interview you for a article on your petition. It will be the top WSJ reporter on the nuclear industry issues and he specializes risk perspectives. It could change the arc of history by telling the WSJ what you know. You might be able to reform the NRC and prevent a another meltdown. The greater public needs to understand what you know. I can't begin to tell the perilous condition the industry is in. You will ruin nuclear power for 75 years if you don't speak in a wider venue.  

I am the nuts case who left you a message on your telephone recently.

Sincerely,

Mike Mulligan

Hinsdale, NH 

cell: 16032094206  

Update 23

I'll bet you Troy was once a nrc inspector at Grand Gulf and/or the boss of the inspectors at the plant.

Update Feb 22

I wonder if the messy scram in Dec 2018 was the genesis of Troy's 2.206? Grand Gulf got a special inspection on it and it hasn't come out yet. Has campaign contributions severely weakened this report? It's coming out soon. If it comes out within the next two week, you got to know this report was the genesis of his 2.206. He just couldn't take it anymore.        

Here is one of Troy's sins. If the NRC would have manhandle Fort Calhoun into a perminant shutdown, it would have sent the licensees a severe message to straighten up. It would have saved the owner of the plant a ton of money on the recovery of this incident, the massive later upgrade, with this obsolete plant. The plant permanently shutdown in June 2016. The flood occurred in 2012. Would be even be seeing Troy's 2.206 on Grand Gulf today if the NRC took severe actions on Fort Calhoun in 2012 and the bus fire. Post 2012 event plant operations and reliability was horrible.       

NRC manager accused of intimidating inspectors, blocking safety concerns

So how can I help NRC government worker Troy Pruett? What is the role of the news media? You need to flood the news media concerning issues with the Grand Gulf and NRC. That is how you pressure the NRC to not to fire or intimidate any NRC employee. All the senior officials and mid level managers are watching this petition, plus the plant inspectors. I am convince most NRC employees think this petition is jaw dropping. If the news media protects Troy, more employees might speak up.

What is really strange, the NRC has a so called professional internal complaint program named "NRC DIFFERING PROFESSIONAL OPINION PROGRAM". Troy has used this internal program before. This concern program is completely and publicly transparent. I am not sure this internal NRC process, what the leadership does behind the closed curtain, is transparent. In the process, he writes up a report and sends it to his boss. I believe this goes through a board of NRC officials. Troy can verbally explain his complaint to the board. Then the board writes up their official response to the complaint. The board is required to publicly disclose the complaint and response publicly. I wonder what advantages you get with the 2.206 versus the Differing Professional opinion program. In the 2.206, he will face a board of his peers. He probably will verbally address the board a few times. All of this will be professionally transcribed and put on Adams. From my opinion, it sounds like he doesn't trust the internal program.         

It is shocking. Well, Troy's unpresented 2.206 made me "ass"ume he was retired. The balls on this high offical guy to write such a report concerning the safety of Grand Gulf.

Division of Nuclear Materials Safety

Director: Troy Pruett
Deputy Director: Linda Howell

Provides implementation, policy oversight, and direction for the materials licensing and inspection programs, decommissioning inspections, uranium recovery inspections, and inspection of permanently shut down reactors and independent spent fuel storage installations (ISFSI). Manages site decommissioning activities and regional activities relating to formerly licensed sites. Manages enforcement and allegation follow-up for materials licensees, sites undergoing decommissioning, permanently shut down reactor facilities, ISFSI facilities and uranium recovery facilities. Responds to events involving above noted programs. Provides coordination and oversight of Agreement State programs and activities.

***Here is me going fishing for a big NRC official.

 From: Michael Mulligan To: McLaughlin, Marjorie Subject: [External_Sender] Re: Links Date: Monday, January 07, 2019 9:51:35 AM
Mrs. McLaughlin,
Reactor status report.

Works perfectly. I had a nice conversation with your today.

By the way, thanks for your service with being a US gov employee. It is a very difficult position and I thank you very much for your hard work. All of you. Don't tell anyone, I love my government with all my heart no matter what party is in control. Keep your chin up in these very difficult times. We are all depending on you in this crisis!!!   

The Democrats have come to town. As you know, the US House is the boss of the NRC. They control your budgets. I would expect to see a increase turnover of your senior leadership.  

I can't begin to tell how bad it would be if we had a nuclear crisis within our national collapse of faith in our institutions and our President Trump problems. I hope all you employees won't go down in history, as our government was tittering on the edge of the cliff, you let a large nuclear accident to develop in our perilous time. 

When TMI occurred in 1979, I was stationed on a experimental fast attack nuclear submarine in the Mediterranean. Believe me, as a stupid young navy sub sailor, the world and especially the USA was in a mess in 1979. I never want to ever hear again, in a set up to a terrible national nuclear power plant crisis that ruined the nuclear industry, the NRC was horrendously dysfunctional and all the insiders new it.  

I'd hope you would be talking to the House politicians in some way to change the arc of moral history. One person can change history. We will all get through this for the better. 

Could you please put my email in Adams. 

Sincerely,  

Mike Mulligan Hinsdale, NH  

16032094206

Here is a once in a lifetime top high official, the gigantic whale I caught. He has been looking over my blog in recent weeks. You notice how his issues follow the articles in my blog. It is as if I scripped the 2.206. Your damn right, I recognized his name right off the bat. I totally forgive him for all the sins he committed while in the industry. He got a clean slate with me now. His 2.206 is a perfect template for getting a House investigation on current events in the industry and the problems of the NRC. Is this the first of many NRC officials turning against the agency.  

Mr. Pruett is the current Director of Reactor Projects in USN RC Region IV. Mr. Pruett joined the NRG in 1992 as a materials health physicist/radiation specialist inspector in Region V. From 1992-present, he held a number of progressively more responsible positions including Resident Inspector at Waterford; Senior Resident Inspector at Clinton and Riverbend; and Senior Reactor Analyst, Plant Support Branch Chief, Reactor Projects Branch Chief, and Deputy Director, Division of Reactor Safety in Region IV. Before joining the NRG, Mr. Pruett was an Instructional Technologist at D. C. Cook and served as a machinist mate in the U.S. Navy. He received a B.S. degree in Human

Here is Troy Pruett explosive 2.206 in its whole. Can you even imagine how much more educated we will all be during the 2.206 process. He writes beautifully.

Troy Pruett PO Box 3425 Grapevine TX  76099

United States Nuclear Regulatory Commission Executive Director for Operations Margaret Doane Petition.Resource@nrc.gov

SUBJECT 10 CFR 2.206 PETITION INVOLVING GRAND GULF NUCLEAR STATION

Dear Ms. Doane:

Pursuant to 10 CFR 2.206 I am petitioning the NRC to take additional enforcement action at Grand Gulf Nuclear Station (GG) by issuing an Order to compel the licensee to take several actions:   1. That GG perform an evaluation of the root and contributing causes for both the individual and the collective issues that have and are occurring at the facility.   2. That GG/Entergy meet with the Commission at least annually to discuss performance concerns and improvement efforts until the corrective action in Item 4 are completed. 3. That the evaluation performed to meet Item 1 conform to the requirements for a full scope Inspection Procedure (IP) 95003, “Inspection for Repetitive Degraded Cornerstones, Multiple Degraded Cornerstones, Multiple Yellow Inputs, or One Red Input,” to independently (a) review the breadth and depth of the performance deficiencies, and (b) perform a graded assessment of the licensee’s safety culture.    4. That GG/Entergy submit in writing to the NRC the results of the evaluation required by Item 1, all licensee commitments, and all corrective actions.  

Reasons for additional enforcement action by the NRC:

1. Several conditions described in MC 0305 for a deviation or transition to MC 0350, “Oversight of Reactor Facilities in a Shutdown Condition Due to Significant Performance and/or Operational Concerns,” have been satisfied.  In particular: (a) The regulatory actions dictated by the Action Matrix are not appropriate and have not been successful in correcting and preventing additional significant performance deficiencies at GG.  (b) An extended voluntary shutdown to address performance issues associated with deficient operations and operator knowledge occurred at GG; however, the NRC did not implement additional regulatory oversight.  (c)  The NRC issued a confirmatory order for multiple operators willfully failing to meet regulatory requirements and the licensee’s actions have been inconsistent; and (d) Numerous significant operational events have occurred at GG.

2. GG/Entergy has demonstrated a longstanding inability to correct systemic problems as described by NRC staff in numerous documents.  Unbelievably, in spite of 6 years of licensee “recovery” plans, performance progressively declined.  During this period, the NRC never, not once, performed a diagnostic evaluation to understand the root causes of continued performance declines at GG.  GG/Entergy has not performed a holistic causal evaluation of the organizational and programmatic performance issues that continue to plague the facility. 

In 2015, 33 violations (statistically deviant) were identified by the NRC.  Eight involved traditional enforcement for impeding the regulatory process (statistically deviant) and one in the area of willfulness.  Region IV staff considered the licensee’s engineering organization to have significant challenges involving a failure to recognize degraded or nonconforming conditions and condition reports that did not accurately describe the associated degraded or nonconforming conditions. These challenges affected the station’s ability to identify problems at a low threshold and to promptly correct conditions adverse to quality.  The licensee continued to implement an ill-fated recovery plan without success.      In 2016, 21 findings (lower but still statistically deviant) were identified.  The Unplanned Scrams per 7,000 Critical Hours PI was White in the 3rd and 4th Quarters.  A special inspection that began in October 2016 identified a finding with potential Greater-thanGreen safety significance associated with the unavailability of the alternate decay heat removal (ADHR).  The licensee misreported the unplanned downpower metric (should have been white).  The NRC identified a station-wide lack of adequate procedures.  The licensee commenced an extended shutdown to retrain all operators on fundamentals of operating a nuclear power plant.  The NRC staff considered the 50.59 process implementation inadequate and that engineering staff had insufficient design basis knowledge.  Thirty percent of the findings over the past two years were related to security.  Additional violations were issued in the area of impeding the regulatory process.   

NRC staff were concerned with occupational radiation safety ALARA planning and work control program in terms of effectively planning and executing radiologically controlled work.   During the assessment period, the inspectors identified a violation of 10 CFR 20.1101(b) for a failure to implement radiation exposure reduction procedures and engineering controls to minimize unplanned and unintended dose.  ALARA related violations are extremely rare in the nuclear industry.  Several work activities during the March 2016 (RFO 20) refueling outage significantly exceeded the initial dose estimates, with minimal or no actions taken to evaluate the basis for the dose overrides and develop mitigating strategies.  

The NRC identified significant weaknesses in operator fundamentals.  This was identified through the operator licensing inspection, the inspection of operator performance during the June 17, 2016, scram, and during resident control room tour observations.   Weaknesses identified were the lack of (1) operations personnel maintaining their roles during events, (2) communication weaknesses and minimization of noise during evaluated scenarios, and (3) understanding and implementation of standing orders and operational decision making instructions.  During the extended shutdown the NRC identified several weaknesses in cross-organizational communications.  Most notable was the lack of consistency in understanding plant risk and schedule coordination between the control room and the outage control center.

The residents performed a trend review in the second quarter of 2016 and identified numerous examples of the licensee’s failure to recognize degraded or nonconforming conditions and generate condition reports that accurately describe the associated degraded or nonconforming conditions.    

The 2016 performance concerns are reflective of broad programmatic concerns in multiple program areas with little to no increase in regulatory oversight.  

In 2017, twenty-seven findings (3 years of statistically deviant results) were documented during the assessment period.  The licensee’s restart plan, included nine corrective actions designated as, “Actions required for restart.”  The inspectors concluded that four were satisfactorily completed, four had received due date extensions that extended beyond the date of the restart without documented justification, and one corrective action was closed without documentation demonstrating that the intent of the corrective action was met.  The licensee identified yet another action plan to address performance gaps, but only implemented part of the plan prior to restart, focusing primarily on the operations department, with some emphasis on the maintenance department.  Performance issues were not limited to the operations and maintenance departments, and the licensee has not fully implemented a strategic training plan for the engineering, chemistry, radiation protection and security departments.

Inadequate/lack of procedures – The licensee implemented efforts to address this issue with the “high intensity training” conducted during the extended shutdown from September 2016 – January 2017.  There was a large focus on procedural adherence and stopping when uncertain or if poor procedural guidance is encountered.  Even though the licensee is continuing their improvement efforts in regards to procedure adequacy and human factor formatting, there have been multiple examples of workers not adhering to procedures and/or stopping when the procedure is unclear.

License commitments and 50.59 process implementation and insufficient design basis knowledge continued thru 2017.  The licensee continued to be challenged with producing quality engineering products, promptly correcting issues affecting safety related components, and ensuring that an adequate engineering interface with maintenance and operations was maintained.  In addition, there were indications that there was a lack of understanding of the design basis of the plant and how that design basis is to be translated into processes and procedures.  There was also a continuing theme of failure to maintain the final safety analysis report accurate and current.  

Corrective Action Program findings that were identified in the 2017 were indicative of a poor performing CAP.  One IP 95001 supplemental inspection was conducted during this assessment period for a White Unplanned Scrams per 7,000 Critical Hours PI, which was White in the 3rd and 4th Quarter 2016.  The NRC concluded that the inspection objectives were not met due to two significant weaknesses and five general weaknesses related to the licensee’s corrective actions to address the underlying performance issues.  Therefore, a White parallel PI inspection finding was opened as an ROP Action Matrix input effective the 1st Quarter 2017. In November 2017, the NRC issued additional traditional enforcement apparent violations involving willfulness, which were associated with general employee training exam proctoring and falsification of non-licensed operator rounds.  In August 2017, four additional Severity Level IV licensee-identified violations in the area of impeding the regulatory process.  In December 2017, one additional Severity Level IV violation in the area of impeding the regulatory process.  This violation involved multiple examples of the licensee’s failure to update the facility’s final safety analysis report as required. 

A finding was issued for the licensee’s failure to operate their gaseous radwaste system within design specifications for years, resulting in non-ALARA effluent releases.  The licensee’s operation of this system outside of the designed off gas flowrate and refrigeration temperature requirements resulted in elevated radiological effluent releases.   Grand Gulf issued yet another recovery plan with three main focus areas.   GG and Entergy Corporate Management indicated that GG performance stabilized.  

However, the NRC staff determined the continued equipment and human performance issues, a weak corrective action program, ineffective work management, and equipment failures involving latent issues, reflected declining performance.  The licensee remained in the Regulatory Response Column of the ROP Action Matrix since the third quarter of 2016 due to a White performance indicator (PI) for Unplanned Scrams per 7000 Critical Hours.     The 2017 results indicate GG was incapable of turning performance. The 2017 performance concerns continued to be reflective of broad programmatic concerns in multiple program areas with little to no increase in regulatory oversight.  The scram rate is extreme for the nuclear industry.  Since January 2016, only 1 quarter exceed 2000 critical hours, reflecting an inability to reliably maintain the facility.    

In 2018, GG continued to exceed the statistically deviant 20+ violation count.  The abnormally high scram rate continued.  The inability to achieve 2000 critical hours in a quarter continued.  Column 2 performance continued.  Another IP 95001 is to be initiated.   The expected 2018 results will likely indicate GG was incapable of turning performance for yet another consecutive year.  The 2018 performance concerns continue to be reflective of broad programmatic concerns in multiple program areas with little to no increase in regulatory oversight.  Plant performance cannot be improved with phone calls and visits from the NRC’s Office of the Executive Director.  To turn performance, the NRC needs to perform a diagnostic evaluation of the facility (IP 95003), understand the causes driving year after year inadequate performance, and implement an inspection program that will lead GG to safe operation.    

3. SCRAMS, Transients and Risk

Boiling Water Reactors, such as GG, typically have a large transient initiator contribution for core damage frequency (CDF) and Large Early Release Frequency (LERF).  The vast majority of operating reactors in the United States have transient initiating event frequencies in the E-1 to E-2 range.  A few have frequencies greater than 1.  

In reviewing the scram, downpower and force shutdown data for GG, it is abundantly clear that the transient frequency at GG is orders of magnitude above industry norms.  Most licensees have zero or maybe 1 transient in an 18 to 24 month operating cycle.  GG has 5 to 10 per year.  As such, the baseline risk values for CDF and LERF at GG should be significantly higher.  However; the NRC has not taken into account the increase in risk metrics, and as a result has not assigned additional regulatory oversight to the facility.    

What is problematic at GG?  According to NRC documents it’s:  (1) untrained operators; (2) inadequate procedures; (3) loss of control of the facility design; (4) lack of understanding of the licensing and design basis; (5) actions that impede and/or prevent
regulatory oversight; (6) inability to implement an ALARA program; (7) difficulty planning, scheduling and completing maintenance; (8) inability to perform causal evaluations; (9) inability to develop meaningful corrective actions; and (10) an inability to implement improvement efforts that restore safety margins.

Risk models fail to account for programmatic deficiencies in licensee performance.  Programmatic deficiencies (errors of commission and omission) must be accounted for using heuristic reasoning in determining a risk informed decision.  However, the NRC has not elevated risk informed decisions to account for broad programmatic failures leading to numerous errors of commission and omission.  As a result, the risk determinations made by the NRC over the past 4-5 years have severely underestimated the risk significance of findings.  The underestimations have in turn resulted in a misapplication of the MC 0305 Action Matrix.         

Region III Allegations and NRC Infrastructure In Disarray

I have been doing a little work with NRC Allegation surrounding the Lasalle nuclear plant. I discovered with their safety relief valve LERs (and LAR), some are missing in the docket. It the NRC and Exelon and NRC so incompetent nobody is enforcing LER reporting. Out of three SRV LERs in ten years at Unit 1, two are missing from the docket. Is it a coverup? This ask is there more LER missing at Lasalle, region III and throughout the nations. What is the extent and cause of condition?

So I dial up the LaSalle inspectors...the line is dead. I have been working with Sara in region III Allegation, can get a hold of here. I call the region III main office and try to get them to connect me to the allegation department. Every time they connect me I get a dead line.  I believe three times. Now I am getting irked. So I call the Washington operation line. I thinking they can connect me to Sara. I believe they tried to connect me to Sara and then somebody else. I had two operations people on the line now. They treated me very professionally. So basically region III was having broad land line problems and especially region III Allegation. So I pipe up to the operations people, now I got a new Allegation concern. You got a broad Allegation's phone reliability problem. That is when the staff fesses up and says we do have allegation phone issue for two days and we are working on it. I mean, you can clearly see it, there is many people here...the NRC instincts is to keep their blemishes or sins close to the vest instead of clearly admit we are having phone issues. Why couldn't they put a notification on the "report a concern page" we are having allegation phone issues. The instinct to hide and make the NRC look good.

So about a hour later after all this I get a mysterious phone call from deep voice and slow talking person telling me I called his line and didn't leave a message. He asked "did you call me"? So I asked, "who are you". He wouldn't tell me his name. I am convinced he is a NRC official. I push him hard on giving me his name. Finally I tell him he is a NRC official. He admits it. So I asked "what department do you work at"? It was like pulling teeth. You get it, he is a NRC employee, he is required to treat me with some level of respect. So I push him a little harder worrying he will hang up on me, We do a little more dancing around nothing, then he tells me his name and he is a project manager. I ask him, ":is one of your plants Lasalle". He says no. I give him the short story about talking to the inspectors at LaSalle and Allegations surrounding SRV issues, we are stumped on why I would call him? Later I am thinking when I called Region III, when the operator desperately  called around to three dead lines to dump, one of those line was his.          

More On the Grand Gulf Scram on Dec 12, 2018

I wonder if the Dec 12, 2018 special inspection results are out? I doubt it.

So two hours after the event started, they are forced to scram. This is totally non conservative. God knows how bad reactor water level was jumping around. So all this hiring below comes from the Scram on Dec 12, 2018 and the deficiencies in plant operations throughout 2018. In this 2016 special inspection below, Entergy voluntarily shutdown to train their operations staff for five months. They brought in many industry experts to figure out what is wrong and retrain the licensed operator. Out of the 2018 scram hiring some 300 hundred employees Entergy is overhauling operations again. Why is this repetitive retraining and overhauling plant operations going on in the worst plant in the nation? Why can't the NRC ROP quickly turn around a bad actor plant in a fairly short time?      

2016 Special Inspection 

The Nuclear Regulatory Commission (NRC) has begun a special inspection at the Grand Gulf Nuclear Station in Mississippi to review circumstances surrounding several recent operational events. The Entergy plant has been shut down since September 8.

On September 23, following maintenance on the residual heat removal system, workers discovered that a misalignment of valves had rendered the plant’s alternate decay heat removal system unavailable. Technical specifications require that the alternate system be available when one of the plant’s two residual heat removal systems is out of service. The system is used to remove decay heat from the reactor following shutdown. The following day, when preparing to restart the reactor, control room operators caused an unexpected increase in reactor vessel water level due to a misalignment of valves.

Three NRC inspectors will spend about a week on site evaluating the cause of the problem and the adequacy of corrective actions to address performance issues. An inspection report documenting the team’s findings will be publicly available within 45 days of the end of the inspection.

“The purpose of this special inspection is to better understand the circumstances surrounding several recent operational events to determine if operator response was appropriate,” said NRC Region IV Administrator Kriss Kennedy. “We will also review the licensee’s corrective actions to ensure that their causes, including associated equipment problems and any contributing operator actions, have been effectively addressed.”  

Entergy hiring 320 for Mississippi nuclear operations 

Associated Press Published 8:29 a.m. CT Jan. 25, 2019 | Updated 9:10 a.m. CT Jan. 25, 2019 

New Orleans-based Entergy says it will add 250 jobs in Jackson, augmenting its nuclear workforce. Spokeswoman Mara Hartmann says some employees will transfer from northeastern nuclear plants Entergy is closing or selling.

The electrical utility says it's also hiring another 70 people at Grand Gulf, increasing workers to 890. Entergy is overhauling the plant's management after operational problems. Grand Gulf supplies electricity to customers in Mississippi, Arkansas and Louisiana...

Downtime at 'aging' Grand Gulf attracts increased scrutiny

Edward Klump and Kristi E. Swartz, E&E News reporters Energywire: Tuesday, December 4, 2018

Tucked near Mississippi's border with Louisiana, deep in Entergy Corp.'s territory, rests the largest single-unit U.S. nuclear power station.

It's called Grand Gulf, and it boasts a 1,443-megawatt capacity.

But it hasn't been acting like a dependable backbone of the power grid.

An E&E News review of federal daily reactor status reports from 2013 through last month found Grand Gulf listed at full power roughly 52.5 percent of the time. It was at zero percent power almost 21 percent of the days studied. On other days, it was at various reduced levels.

Does that sound like a baseload plant?

"No," said Ted Thomas, chairman of the Arkansas Public Service Commission.

New Orleans-based Entergy has a 90 percent stake in the plant through an entity called System Energy Resources Inc. Cooperative Energy in Mississippi has the other 10 percent...

They bungle this event below as a whole and control of reactor water level. It is not the first time they lost control of water level. You notice how components that feed the vessel (RCIC) are having mechanical issues delaying the control of water level.  

Licensee Event Report 2018-010-00, Reactor Manual Scram due to Main Turbine Bypass Valve Drifting Open 

Grand Gulf Nuclear Station (GGNS) Unit 1 was operating at approximately 100 percent power in Mode 1. There were no Structures, Systems, or Components that were inoperable that contributed to this event.
B. DESCRIPTION
At appoximately 1200 hours CDT on Wednesday, December 12, 2018 while operating in MODE 1 at appoximately 100 percent power the GGNS·Main Steam Bypass Stop and Control Valve 'A' [JI] began drifting open. The valve began to modulate between O -10% open over the course of 90 minutes. After 90

Can't you hear the CEO telling the licensed operators, "I don't want you shutting down for any reason". We are getting into a lot of outside trouble with our disgraceful capacity factor and gads of shutdowns. One more scam or down power and I am going to fire you all. I am exaggerating here a little, but I suspect this kind of upper level pressure with the two hour delay in fixing the B/P valves. The delay was the operators and other techs trying to troubleshoot to problem and hopefully going to fix the issues before the plant scram. And the indications was worsening by the seconds.  

minutes, the valve began to open at an increased rate, reaching approximately 50% open. The reactor was manually scrammed at 1351 hours. The Main Steam Line Isolation Valves [SB] were manually closed as a mitigating action to control reactor pressure vessel rate of depressurization and cooldown. Reactor pressure was controlled through the use of the Safety/Relief Valves [SB] and ultimately the Reactor Core Isolation Cooling (RCIC) System [BN].
During the scram recovery, at 1358 hours the operator proceeded into the steps for a controlled start of RCIC. The expected RCIC injection response was delayed due to discharge pressure indication and governor valve light indications were not as expected. Therefore, the operator prepared to initiate the High Pressure Core Spray (HPCS) System [BG] based on current reactor water level and its trend.
During preparation to initiate HPCS, the operator noted that RCIC had started to inject but reactor level was in the low end of the d~sired control band at-24.811 Wide Range (WR) with a downward trend and'current RCIC injection was not arresting the decreasing trend in a timely manner. After evaluating the reactor water level and rate of change, the operator completed manually starting H PCS injection at 1408 hours. At 1409 hours, the HPCS injection was secured with reactor water level at 7.4" WR and trending higher and RCIC still injecting. RCIC and Safety/Relief Valves were utilized for reactor water level control until RCIC was placed in standby at 1645 hours. 

As far as the delay to shutdown, there is nothing to fix on failed linear variable differential transformer below. I wonder how old it was? They can't operate for long with that kind of problem. The delay in scraming provided no benefit to prevent a scam or shutdown. They should have emediately scrammed and I suspect they were required to emediately shutdown per procedure. Not wait two hours to do the required thing...    

The direct cause of the event was a failed Linear Variable Differential Transformer (L VDT) in the actuator for the Main Steam Bypass Stop and Control Valve 'A' that directy resulted in the inability of the valve primary controller to properly position the valve. Failure of the L VDT resulted in a constant error signal being present at the controller, which allowed the valve to integrate open over time.

Typical Inspection Report for a Plant Heading Towards The Junk Yard

Relaxation with NRC rules and inspections as a plant is near permanent shutdown?

Fuel failures, Bum CRDM and incompetence with detecting cracks in the reactor head...

February 13, 2019

 SUBJECT:  PALISADES NUCLEAR PLANT — NRC INTEGRATED INSPECTION  REPORT 05000255/2018004

Is This Hope Creek Going To Plus or Minus 5% With SRV Testing

Just Remember, Hope had gone from plus or minus 1%, to 3% and heading to 5% over setpoint drift. It is a massive relaxation in testing requirement on these defective and unstable valves. The Hope is they will be permanently shutdown in a few years over financial problems.

ML19031B845 isn't in the docket yet? But this guy gives you a idea of the magnitude of relaxation.  

 From: Kim, James Sent: Friday, February 15, 2019 12:32 PM To: Duke, Paul R. Cc: Thomas, Brian J. Subject: Acceptance Review Result: Hope Creek-Relief Request to USE ASME Code Case OMN-17  (L-2019-LLR-0010)
Mr. Duke,
 By letter dated January 31, 2019 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19031B845), Public Service Enterprise Group Nuclear, LCC (PSEG, the licensee) submitted a relief request for Hope Creek Generating Station in accordance with 10 CFR 50.55a, “Codes and standards,” paragraph (z)(i) requesting approval for alternate rules for testing ASME Class 1 Pressure Relief/Safety Valves for the fourth 10-year inservice inspection interval.
 The NRC staff has reviewed your application and concluded that it does provide technical information in sufficient detail to enable the NRC staff to complete its detailed technical review and make an independent assessment regarding the acceptability of the proposed relief request in terms of regulatory requirements and the protection of public health and safety and the environment. Given the lesser scope and depth of the acceptance review as compared to the detailed technical review, there may be instances in which issues that impact the NRC staff’s ability to complete the detailed technical review are identified despite completion of an adequate acceptance review. If additional information is needed, you will be advised by separate correspondence. 
 The NRC staff has estimated that this licensing request will take approximately 120 hours to complete. The NRC staff expect to complete this review in approximately 8 months, which is October 2019 in support of the fall 2019 refueling outage. If there are emergent complexities or challenges in our review that would cause changes to the initial forecasted completion date or significant changes in the forecasted hours, the reasons for the changes, along with the new estimates, will be communicated during the routine interactions with the assigned project manager. 
 These estimates are based on the NRC staff’s initial review of the application and they could change, due to several factors including requests for additional information, unanticipated addition of scope to the review, and review by NRC advisory committees or hearing-related activities. Additional delay may occur if the submittal is provided to the NRC in advance or in parallel with industry program initiatives or pilot applications. 
 If you have any question, please contact me, James Kim, at James.Kim@nrc.gov or 301-415-4125.
 James Kim, Project Manager Branch 1, Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission

Why Has River Bend Been at 75% Power For Forever

Junk Plant Hope Creek Safety Relief Valve Cover-Up

Reposted from 1/29

Update Feb 14

Meeting a 10am this morning. 

Update Jan 30

I forgot to brag about my capabilities. I am solely responsible for pushing the NRC into making the set point drift a issue with the BWROG. I caught the drastic increase of setpoint drift LERs. Basically I said the SRVs over time with setpoint drift and leakage, unreliable parts...was a threat to the industry. It is interesting the NRC only choose the set point drift. The industry generally withholds all information about valve leakage and abnormal temperatures. So it is really hard to figure out how much leakage is going on in the industry by outsiders.

Check out my concerns at Hope Creek and Pilgrim in Adams? These valves are defective and they are sitting on a precipice of hell.       

Update

Oh, this guy is in my cell phone calendar. 

January 29, 2019 Title: Public Phone Call with the Boiling Water Reactor Owner's Group (BWROG) Regarding the Target Rock Safety Relief Valve (SRV) Setpoint Drift Issue February 14, 2019, 10:00 AM to 11:00 AMDate(s) and Time(s):
Location: Teleconference
Category: This is a Category 2 meeting. The public is invited to participate in this meeting by discussing regulatory issues with the Nuclear Regulatory Commission (NRC) at designated points identified on the agenda. Purpose: For the BWROG to provide a status update of activities being taken to address the Target Rock SRV Setpoint Drift Issue. Contact: Joe Golla 301-415-1002 joe.golla@nrc.gov
NRC NRC Staff Participants: External Boiling Water Reactors Owners Group
Teleconference:
Bridge Number Pass Code (888) 606-7810 16608

***The magnitude of the non performance issues here are astonishing. Most of the below information is new. Most has not been publicly documented. This reminds me of Pilgrim before their 2015 blizzard trip. The vast amount of non performance was secret. Then three failed. These valves are very delicate for their harsh safety environment. These safety valves may cycle up to 400 times in a accident.  

January 28, 2019

SUBJECT: HOPE CREEK GENERATING STATION UNIT 1 – INTEGRATED INSPECTION REPORT 05000354/2018004 

) SRV Main Seat Leakage In NRC IR 2018002, the Semi-Annual Trend review section documented multiple high SRV tailpipe temperatures and conclusions that two of these SRVs, ‘H’ and ‘K’, were exhibiting signs of main seat leakage.  Then, in NRC IR 2018003, an annual sample conducted for ‘H’ SRV and ‘D’ MSL issues documented that on September 5, 2018.  On that date, PSEG also initiated NOTF 20803213 recommending that engineering review the conclusions and corrective actions from a 2014 causal evaluation (ACE 70168360) due to the inspector’s questions.  Upon further review, the inspectors noted that PSEG had not taken action on NOTF 20803213 because even though there was automatic relief valve seat leakage it had not progressed and begun generating cyclic noises associated with condensate induced water hammer.  In 2014, these noises associated with condensate induced water hammer occurred in the torus approximately ~20 times/min.  October 1, 2018, the inspectors noted that PSEG initiated NOTF 20806044 for degrading conditions associated with the ‘H’ SRV main leakage, and then documented the reoccurrence of the condensate induced water hammer in the torus in NOTF 20814836 on December 20, 2018.  As of December 31, 2018, PSEG initiated actions to develop an adverse condition monitoring (ACM) plan and operation technical decision making (OTDM) document for the issue.  In addition, PSEG initiated NOTF 20816775 when the inspectors determined that the ‘H’ SRV main seat leak rate data from August to December 2018 was incorrect and did not include peer checks.

Safety Valves

Got three of these guys. Basically these valves are similar to the SRV. It has no remote function. These guys got a last ditch function with maintaining pressure in the vessel. It would be a horrible accident if these guys failed.  

December 10, 2018 

Licensee Event Report No. 2018-003-00 Cooper Nuclear Station

Safety Valve Failure Results in Loss of Safety Function

The pressure relief system includes three American Society of Mechanical Engineers code safety valves · (SV) [EIIS:SB] which are located on the main steam lines [EIIS:SB] within the drywell [EIIS:NH], between the reactor vessel [EIIS:RPV] and the first main steam isolation valve [EIIS:ISV]. The SVs provide protection against over pressurization of the nuclear system and discharge directly into the interior space of the drywell.
Technical Specification (TS) Limiting Condition for Operation 3.4.3 requires the safety function of three SVs to be operable. The nominal set pressure and tolerances for these valves are established in CNS TS Surveillance Requirement (SR) 3.4.3.1. 

PUBLIC MEETING WITH BOILING WATER REACTOR OWNERS’ GROUP on SRVS

Target Rock Safety Relief Valve Setpoint Drift Issue for Boiling Water Reactors September 12, 201

Agenda
• Background • Safety Relief Valve (SRV) Design Function • Safety Significance • Technical Specification (TS) Compliance • Industry Actions Considered in Past • Next Steps • Boiling Water Reactor Owners’ Group (BWROG) Feedback

Background
• Purpose:  To discuss Target Rock 2-stage SRV setpoint drift issue for boiling water reactors (BWRs). • Licensees continue to experience a large number of surveillance test failures with 2-stage Target Rock SRVs. • Typically TSs allow only one SRV failure. • TS operability allowance for setpoint drift for most plants is  ±3 percent. • As found setpoint drift for a number of BWRs ranges between +3 to +10 percent. – Most significant instance being a setpoint drift of +18.5 percent.

Background (cont.)
• Originally, the issue was addressed by Generic Safety Issue (GSI) B-55, “Improved Reliability of Target Rock Safety Relief Valves.” • GSI B-55 concluded the following: – Safety significance is low. • There is margin to reactor coolant system stress limits. – Industry was already pursuing actions to correct the setpoint drift. • Staff was satisfied with industry actions to resolve issue. – Regulations already require licensees to correct the setpoint drift (no new regulatory requirements are needed). • TSs, 10 CFR Part 50 Appendix B, 10 CFR 50.55a, and 10 CFR 50.65. • Therefore, GSI B-55 was closed in December 1999.

 SRV Design Function
• The SRVs are part of the nuclear pressure relief system and, in part, prevent overpressurization of the nuclear process barrier.  • A select number of SRVs are used by the automatic depressurization system (ADS) to rapidly decrease reactor pressure during specific small-break loss-of-coolant accidents during loss of high-pressure injection scenarios.  • The setpoint drift issue does not affect the ADS function.

Safety Significance The NRC staff reviewed the licensee event reports (LERs) considering the following design aspects for determining the safety significance for SRVs that do not open at their expected setpoints:
• ASME Code pressure/service limits on the primary system. • Hydrodynamic loads on SRV discharge piping. • Performance of high-pressure injection systems.

Safety Significance (cont.)
Based on the review of LERs, the NRC staff determined the safety significance associated with Target Rock 2-stage setpoint drift to be low.

TS Compliance
• In the Standard Technical Specifications for General Electric BWR plants, Limiting Condition for Operation (LCO) 3.4.3 states: “The safety function of [11] S/RVs shall be OPERABLE.” • SR 3.4.3.1 states: “Verify the safety function lift setpoints of the [required] S/RVs” are within a specified range. • Surveillance Requirement 3.0.1 states that “[f]ailure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO.”

TS Compliance (cont.)
• Following the guidance of Inspection Manual Chapter (IMC)-0326, “Operability Determinations & Functionality Assessments for Conditions Adverse to Quality or Safety,” if there is not a reasonable expectation of operability, the SRVs should not be considered operable. • NRC staff considers the repeated failure of Target Rock SRVs a challenge to a reasonable expectation of operability.  This could lead to determination of inoperability and noncompliance with TSs.

Past Industry Actions Industry has identified corrosion-induced oxide bonding to be the cause of the current setpoint drift issue for 2-stage Target Rock SRVs. The licensees have tried the following options since the closure of GSI B-55, but with limited success: • Application of platinum coatings to SRV pilot valve discs. • Change the pilot valve disc material to Stellite 21 in an effort to prevent corrosion bonding. • Enhanced SRV insulation to reduce corrosion and improve reliability. • Return to modified Target Rock 3-stage SRV (subject to downward setpoint drift concerns).
10

Owners group slides 

Craig Shepherd (DTE) – Committee Chairman
BWROG/NRC Meeting September 12, 2018
Copyright 2018, BWR Owners’ Group, All Rights Reserved
BWROG Target Rock SRV Performance Improvement Committee
2
History/Scope
Formed in 2016
Committee Scope:  address the common causes of repetitive Target Rock 2-stage SRV as-found set-point test failures in the fleet. • Technical Exchange Meetings:  share site set point drift performance, best practices, roadmap planning • 2-stage valve focus • Scope focused on setpoint drift
Membership:  DTE/Fermi, Duke/Brunswick, Exelon/FitzPatrick, NPPD/Cooper, PSEG/Hope Creek, TVA/Browns Ferry
Copyright 2018, BWR Owners’ Group, All Rights Reserved
3
2017/18 Activities
• Industry-shared IBAD procedure (application of Platinum to disc surface) • Autoclave Screening Test - used to help develop sputtering application process of Platinum on test coupons and comparison to IBAD.  Obtained positive results. • Plasma Enhanced Magnetron Sputter Coating of (Quantity 3) pilot discs with Platinum.  Performed steam validation testing with positive results. In process of obtaining BWROG product for utilizing Sputtering for application of Platinum on SRV pilot discs. • Static Autoclave Material Screening - baseline conditions of corrosion bonding with control group and screening other materials. (Started Aug. 24, 2018)
Copyright 2018, BWR Owners’ Group, All Rights Reserved
4
2019 Planned Activities
Test different thickness of (sputtered) Platinum coated on pilot discs in valve lift tests. • Sputtering opens process space for different thicknesses of Platinum Coating. • Potential for fleet usage – Know that current thickness of Platinum coating provided step-improvement in set point drift performance.  – Does increase in thickness provide more protection from corrosion bonding?
Copyright 2018, BWR Owners’ Group, All Rights Reserved
Initial scoping effort to understand current Tech Spec Limits and alternative licensing approaches. • Not a funded project at this time. • Initial discussions among multiple BWROG committees.
LER Reduction
Copyright 2018, BWR

Example of NRC Risk Perspective Corruption

They are basically substituting bureaucrat's expert judgement for science, engineering and facts. Generally the NRC inspectors are not experts over the plants compared to the plant employees. So how does a guy like me know the exerts credential, training and skills are appropriate for the task? Is all the uncertainty wasted out? 

So at the bottom of the pile of horse manure on this risk perspectives, all you got are humans making judgments about safety. This is no way the system keeps these experts straight...they are the NRC untouchables. The unconstrained gods of nuclear safety... Dirty human judgements are behind everything about risk perspectives, and I have massively decreasing confidence surrounding our professional class...

This all is sneaky deregulation and weakening of the controls surrounding the industry. The politicians all want plausible deniability with the acceptance of campaign contributions. If a terrible accident happens, the politicians don't want to get blamed or our political system in general. To for fill this style of corruption, they create two systems. One is defined by congressional  regulations and other is defined as a secret system were the NRC bureaucrats appease the politicians and utility big wigs pulling the strings  unseen by any political oversight. The professional judgement thing here is... really, is the nuclear plants being regulated and overseen by the professional class wild west gunslingers for hire.        

February 07, 2019

MEMORANDUM TO: Sean E. Peters, Chief  Human Factors and Reliability Branch  Division of Risk Analysis  Office of Nuclear Regulatory Research
 FROM: Jing Xing, Senior Human Performance Engineer  /RA/  Human Factor and Reliability Branch  Division of Risk Analysis  Office of Nuclear Regulatory Research
 SUBJECT:  UTILIZATION OF EXPERT JUDGMENT TO SUPPORT HUMAN RELIABILITY ANALYSIS OF FLEXIBLE COPING STRATEGIES (FLEX)


This memorandum transmits work performed for the Office of Nuclear Reactor Regulation (NRR) related to the use of expert judgment to support human reliability analysis of flexible coping strategies (FLEX).  To date, the research products developed by the Human Factors and Reliability Branch (HFRB) along with the staff of NRR include: 1) The presentation on the topic to the 2018 Probabilistic Safety Assessment and Management Conference, 2) A draft paper on the topic submitted to the 2019 Probabilistic Safety Analysis Conference, and 3) A brief summary of the results of the expert elicitation on FLEX human reliability analysis.  Dr. Jing Xing from HFRB and Ms. Michelle Kichline from NRR reviewed these documents and concluded that the documents contained materials useful for the NRC’s risk-informed licensing reviews related to implementation of FLEX equipment and, therefore, recommend that they be made publicly available. If you have any questions about these materials, please contact me. 

Enclosures: As Stated


CONTACT: Jing Xing, RES/DRA  

Junk Plant Seabrook

With concrete degrading in critical parts of Seabrook, environmental advocates urge to delay renewal of license

David L. Ryan/Globe Staff/File/2011
The Seabrook Nuclear Power Plant in Seabrook, N.H.
By David Abel Globe Staff February 12, 2019


NEWBURYPORT — Concerned about growing cracks in the concrete containment dome and in other critical parts of the sprawling complex at the Seabrook Nuclear Power Plant, a group of activists here has been urging federal regulators to postpone a planned extension of the aging plant’s operating license.

With the help of lawmakers from Massachusetts and New Hampshire, they recently won a reprieve.

Officials at the Nuclear Regulatory Commission agreed last month to delay their renewal decision and meet with local residents on Wednesday in Hampton, N.H., to discuss whether the plant should be allowed to continue producing electricity 20 more years after its current license ends in 2030.

Now, the activists are planning to file an emergency petition with the government, seeking immediate action “to ensure that the NRC will uphold its duty to protect the public,” said Natalie Hildt Treat, executive director of the C-10 Research & Education Foundation, which for years has been monitoring radiation from the plant.

The petition, which the group plans to file this week, demands that regulators delay their decision on the license extension. “We think the NRC made a mistake when it concluded that [extending the license] would pose no significant hazard to public safety,” she said...