Pilgrim's failed Target Rock SRV

New April 5, 2:30pm
The OIG gave me a call today.

...He humiliated and disrespected me with this phrase " if your were a decent whistleblower" you would have a complete report.

You know what I say, record and transcript every conversation I have with NRC official. If you were with me on my conversation you would see how disgraceful and uneducated some officials are.

Mostly the front line NRC inspectors and their bosses are really decent people...but the support people like Allegation and the OIG are atrocious and with their knowledge of the nuclear industry. They generally don't have the skills and are not trained to talk in a non threatening manner and have a open discussion.

This guy began exactly like the Allegation...what was the LER nmber?
  
...So were talking about target rock and why components immediately failed on new installs.

This guys didn't know what a safety relief valve did in a BRW. I had to educate him on its function.

You know what, these are really complicated components and organizational issues. You just can't come into a conversation with me without deeply researching my issues or I have to give you grammar school class in BWR designs. Both Allegation and the OIG did this.

If you don't do your background work before you get to me...i am going to lose you within the first five minutes.

The NRC OIG guy said its not fraud waste, misconduct or abuse within the rules of the OIG...so it a licensing or NRR thing. I said believe me i got it with your NRC people, you are going to pass me from one department to another because some NRC employees are too lazy to do their jobs. I am going to have to explain myself 100 times to different departments and NRC employees, who don't even know what the function of a SRV is.  ...The NRC is doing one of those teenager la la la la deals while covering their ears to the obvious.

Basically, I asserted LER's are insanely incomplete and inaccurate...

...I would say i was exposed to a militaristic use of language to disrupt communications....the use of rules and regulations in way to disrupt communication and knowledge of the problem to the
public. It is using words, language, rules and regulations, indeed government as weapons against the innocence...the intent is deny public participation with government. They militaristically trying to rule me and everyone out of public participation.

I think what we got here is systemic breakdown with the utilities and NRC to control vender repair, new parts and basic off site engineering services. I think these vendor component and engineering suppliers are not required to tell the truth. I would say since I been hitting them on these issues the NRC has tried to come to grips with their vender service provider problem.

Bottom line, they are having trouble getting replacement parts on these obsolete plants. Companies have gone out of business and ceased production streams, and the new deal is they are hiring companies who specialize in doing "reverse engineering" on replacement parts that are dangling without any new parts stream.

...As example, all the new Mitsubishi kids are making the San Onophe SGs and the old experienced engineers have retired or died.  

New March 28
I backed out of the NRC allegation process. They got hyper legalistic and evidence thingy on me...they knowing that the agency and the utility had all the cards. I said the Peach Bottom 2.206 administrator sent my issue into allegation...I didn't call in allegation on my own. I thought it was going to be a conversation between me and agency...not this one way deal where if i said i sneezed then I had to prove I sneeze. I asked, should I have brought my lawyers and engineers into the deal.

I didn't think the Allegations process was fair and opened...it was hyper legalistic and hyper regulatory rules thingy where you couldn't sneeze if it wasn't in the rules. The Alligation team went cold into this not even researching my involvement with VY and Peach Bottom, and the LERs and inspection reports.   

I said I withdrawal my concern and I don't want to be updated about this. They told me you can't withdrawal a concern once one was given to the NRC....but you can be anonymous.

  ...At the bottom of it over VY and the Peach Bottom SRV issue, I spent days researching everything i could about the SRVs. I spent a hour and half each with both inspectors at VY and Peach Bottom for a total of four plant inspectors and three hours talking to me. I knew the territory and what I was talking about...I was frustrated that these four officials went cold into this meeting. Then they played the, mike this thing is evidence driven and we got to know the LER number and we got to know who the VY inspector's names are. It was humiliating and disrespectful for me. There was one official talking to me as I was discussing my issue, then none of the other three officials could even do quick search on the VY docket for the LER document number to get us past the sticking point. What BS!

I got a e-mail trail from Don, lets schedule a meeting beginning last thurs. I say I ready right now, tomorrow and any time at your convenience next week. Just set the time and date and i will be there. I wanted to make it easy for him. Then I get a e-mail tues saying I can't find anyone to have a meeting with you without any explanation. Next day he tells me the following day the meeting is on, what time.

They don't even have the courtesy on their own to read my 2.206s and transcripts surrounding the VY and Peach Bottom seals. These Allegation idiots have in their documents I make a recent allegation by phone about VY seals again and they are the ones who made the VY inspectors call me without going though the Allegation process.

That is another more specfic information not disclosed in the VY LERs or inspection reports...the 400 degree vitol seals.

We should go through the VY seal LER and update, then contrast what got in the NRC inspector report and then what came out in the NRC inspectors meeting with me. We should then discuss what should have been disclosed in LERs and further inspection reports. As far as i am concerned, the inspectors at both plants should be on the phone bridge. We should go over it point by point and not have any other commitment to rush anyone, until everything is completely hashed out. We should do the same thing with the Peach Bottom LER.

Again, we don't have public participation with the NRC and utilities around our homes, unless all the aspects of the problem is out in the public arena.

March27 

Mr. Mulligan:

I have been unable to contact the appropriate NRC technical staff, for a telephone call with you. I will contact you when I know more.

Sorry for the late information.

v/r,

Ron Schmitt

USNRC

New

From: "Schmitt, Ronald"
To: "Michael Mulligan (steamshovel2002@yahoo.com)"
Cc: "James, Lois"
Sent: Thursday, March 22, 2012 8:33 AM
Subject: Time to discuss your concerns (RE: Quality Assurance program at Target Rock)
  
Dear Mr. Mulligan:

This email is in regards to your email that you sent to Mr. John Hughey, of the U.S. Nuclear Regulatory Commission (NRC) on March 17, 2012. In your email, you expressed concerns regarding the Quality Assurance program at Target Rock, as a result of failed safety relief valves at Vermont Yankee, Pilgrim and Peach Bottom nuclear power plants.

We would like to set up a call with you so that our staff can ask additional questions to better understand your concern.

Please respond to this email with some days and times that are convenient for you so that I can schedule the call.

Thank you for informing us of your concern. If you have any questions, please contact me or Ms. Lois James at .

 

Ronald V. Schmitt

Office Allegation Coordinator

Office of Nuclear Reactor Regulation

U.S. Nuclear Regulatory Commission

Pilgrim's failed Target Rock SRV
Licensee Event Report 2011-007-00: Safety Relief Valve leakage

So you get it, with the SRV threaded seals at VY and Peach Bottom they failed within the first cycle from degradation due to poor quality seals. Now at Pilgrim another SRV fails with months due to leakage and they blame poor pilot valve workmanship at Target Rock.

Sounds like systemic QA problems with Target Rock. I request a investigation of Target Rock and all similar safety valves.

I talked to your nice Peach Bottom inspectors over increasing the SRV's set inaccuracy from plus or minus 1% to plus or minus 3%. Does the NRC have any evidence that decreasing the margin of set point accuracy reduces the entry into applicable tech spec LCO. I see all the utilities have different guesses on what cause pilot valve bonding. Some say its oxygen or hydrogen that sets up bonding on the surfaces, others say its just bonding and they don't care. Others again say its outside insulation and temperatures that sets it up.

As far as the statement that increasing the relief valve testing set point inaccuracy will reduce entry into a LCO, I don't think that is true. The limited data I see indicates when you increase testing set point inaccuracy, you increase entry into a LCO in the long run.

PILGRIM NUCLEAR POWER STATION - NRC INTEGRATED INSPECTION

REPORT 05000293/2011- 005

October 1, 2011 through December 31 , 2011

 The inspectors selected the issues of safety relief valve (SRV) and automatic depressurization system (ADS) valve leakage and setpoint test failures as an inspection sample for in-depth review to assess the corrective actions taken by Entergy to address these long-standing issues. Entergy's corrective actions included replacing the four ADS valves and the two safety relief valves with a Target Rock three-stage relief valve design, increasing the capacity of the two safety relief valves, and amending the license to allow for a set-point pressure band of +/- 3%. Additionally, the new valves were equipped with multiple leak detection temperature indicators.

The inspectors reviewed procedures, condition reports, engineering evaluations, modification packages, post maintenance testing, and license amendment correspondence, and interviewed plant personnel to assess Entergy's problem identification, evaluation, and corrective action effectiveness with respect to SRV and ADS valve leakage and set-point drift. Additionally, the inspectors reviewed the technical specifications and UFSAR to assess the change to the relief valves with respect to design and licensing bases requirements. Documents reviewed are listed in the attachment. Findinqs and Observations

Findinqs and Observations

No findings were identified.

The ADS valves and SRVs were originally a two-stage Target Rock-type design, consisting of a pilot-stage assembly and a main-stage assembly. Industry Operating Experience had shown that two-stage Target Rock relief valves exhibited some amount of pilot-stage leakage during plant operation. Additionally, the technical specification allowed valve setpoint pressure band was +/- 1%, which left little margin to maintain the valves operable in the event of valve leakage. As a result, SRV and ADS valve pilot stage leakage were challenges throughout the plant's operating history and caused several forced shutdowns.

The inspectors noted, based on nuclear industry operating experience, that the replacement of all the ADS and SRVs with the three-stage Target Rock design was a significant positive step in reducing the likelihood of relief valve seat leakage.

Additionally, the inspectors noted Entergy's evaluation of an expanded relief valve setpoint pressure band and subsequent license amendment have resulted in significantly more operating margin for the plant in the event that a valve does exhibit signs of leakage. Finally, the inspectors determined the addition of several temperature monitoring points on the valve would allow Entergy to more effectively evaluate the operability of the valve should any leakage occur.

Mike Mulligan's US Government Renaissance

First published as comments in the NYT's in: The Nurture of Nuclear Power

I always thought the problem with nuclear power was ideology not technology. The dominant control ideology of the industry has been increasingly the hard right wing conservatives and this ideology is dominant at every plant. There are very few democrats at any of these plants and certainly even less as you go up the management ranks.

The model has defaulted into a autocratic and a decentralized form...every plant is a one off. We serve profits and self interest, and not the greater good of our nation.

The true benefits of nuclear industry has never been shown. I propose a government take-over of the 25 Fukushima plants in the USA. As a national security issue, we should replace those plants with brand new identical models. Lets begin another grand experiment. They would be large plants and centrally controlled in the initial construction and early operation phase. Imagine the efficiency if these plants were built to one set of codes from both the regulator and the designer/builder stand point. It should be a government controlled and modeled like the TVA project.

What if we woke up one day and we discovered government could be more efficient and 'just' than any corporation...or at least could complete with them.

President Obama could say these plants are a dire threat to the USA and the only way out is to replace them. We just about got negative interest rates with QE2 and why couldn't we come up with a revolutionary borrowing mechanism. It would be a giant jobs and public works project. It would split the Republicans this fall and who knows the size of the political coalition we could create for the nation?

There is more value than the traditional economic benefits than cheap and reliable electricity over a project like this. We should value a project like this for how much advanced education and advance managerial experience it drives into our nation. How much advanced intellectual experienced it drives into all the employees who are associated with this voyage. This is, and always was, the real wealth of our nation!

An Unforgettable Night - ATC Operator Event at Palisades

There are a lot of these CRDM seal shutdowns at Palisades. No other plant in the nation has these kinds on troubles. These complex seal repair shutdowns have been involved with unpredictable interactions and incidences.

A initial plant design defect that is not corrected is driving enormous complicity into the control room and their employees are being overwhelmed by it.

I told the NRC this was a very important event for the industry and there should have been reports to the industry about what went on this night a Palisades. What nobody can get away from, the agency doesn't have the capability to capture events in such detail as this employee did.

This event occurred on Oct 23, 2010 and Palisades has had another seal shutdown on Jan of this year. We got to see this letter for the first time this March 8 2012.

I believe the event was entered into the Palisades ROP as a question of why did one of their employees leave the control room. Nobody has yet answered why were they winging this vacuum fill procedure, why did they lose reactor water level for a period of time worrying about vortexing and why did they allow so many distraction going on while they were manipulating core water level during a high risk alignment of the plant.


An Unforgettable Night - ATC Operator Event at Palisades

Introduction
On the early morning of October 23, 2010, I left the ‘at the controls’ area of Palisades nuclear plant without a proper relief or turnover. Up until that time, I had always considered myself to be a very conscientious and safe operator. I never imagined that I would leave the control room without a proper turnover – but I did. I hope by writing this article, others can learn from my mistakes and avoid making the same or any similar mistake. With that objective, this article describes the events that led to my actions, the effect this event has had on me, the lessons I have learned, and my experiences with the NRC investigative and enforcement processes.

Description of Events
Palisades was nearing the end of a refueling outage, which was on course to be our most successful ever due to the short duration and large number of major projects completed. We were about to enter our third reduced inventory period to perform a vacuum fill operation.

This vacuum fill procedure was relatively new for Palisades, having successfully

performed it for the first time during the previous refueling outage. It is a procedure to lower the water level in the reactor to the middle of the hot leg, and then draw a vacuum on the Primary Coolant System (PCS) to evacuate air and other non-condensable gasses. We devised this procedure in an effort to improve plant reliability—specifically to extend the life of our control rod drive mechanism pressure boundary seals.

Excerpts:

During the brief, I mentioned that during my turnover briefing, I heard that the reactor head did not have a vent path.

We lined up the drain path and commenced, but the PCS level indications did not respond as expected and we stopped the drain.

During this period, we had Auxiliary (non-licensed) Operators (AO's) troubleshoot the problem by verifying level glass and vent path lineups.

Concurrent with the PCS drain, most of the control room staff was at the Infrequently Performed Test and Evolutions (IPTE) brief for the vacuum fill work.

While this occurred, we had more issues with the EHC system; a reactor operator called the control room and stated he was not sure we had a good EHC flow path.

I felt this was a problem that required reviewing the prints and was too distracting with the PCS drain taking place while in reduced inventory, so I handed off the call to a different operator.

I told a Senior Reactor Operator that we were having issues with the EHC system, but he was busy overseeing the PCS drain.

A few moments later, however, the EHC low level alarm came in.

Several minutes later, the low level alarm was still not clear and I was concerned about a possible leak, so I secured the pump. I quickly heard back that there was a spill...

Consequently, they requested that the pump be placed in service for their vendor work, stating the cooling and flow path issues were solved.

This was all happening while the PCS level indication troubleshooting was in progress.

Eventually, Maintenance workers removed some temporary flange covers on the reactor head for a better vent path.

The drain that we initially briefed to be about 17 minutes ended up taking over three hours.

After we got to mid-loop, I lowered shutdown cooling flow to about 3100 gpm, which was the high end of the vacuum fill requirements.

...commented that he did not like the pace I was making my adjustments.

The previous time we performed the vacuum fill procedure, it worked flawlessly, but this time was different.

There was indication of a leak somewhere that was intermittently venting and allowing pressures to equalize throughout the system.

While Operator 1 and other members of the control room staff were troubleshooting the problems with vacuum fill, we received the low critical service water alarms and entered a procedure for "Loss of Service Water."

...the Control Room Supervisor (CRS) had to come down off the CRS’ “island” and speak with me directly to ensure effective communications during this very active period in the control room.

We soon learned that the work control center sent out a lube and stroke PM for the main lube oil service water isolations, and that was probably the cause of the low header pressure.

During the hold, I noticed the shutdown cooling flow rate had slowly started to trend down to 2900 gpm on its own and I voiced my concerns to the Control Room Supervisor. I showed him the one minute shutdown cooling flow rate trend on the Palisades Plant Computer (PPC), and said there may be some vortexing or other flow phenomenon that I did not understand.

He stated we could also enter the LCO, if necessary.

Suddenly, however, PCS level indication sharply fell to an elevation below the bottom of the hot leg.

As PCS pressure rose, the primary coolant level slowly recovered to an expected value and I received the order to raise the PCS level to exit reduced inventory.

By this time, it was early morning and we exited reduced inventory during SRO turnover.

Byron Switchyard Insulator 2.206

So what would prevent all the defective switchyard insulators from breaking and shorting in a heavy storm, tornado or earthquake and then causing another LOOP...

The last LOOP at the plant was extraordenary, in that the plant was disconnected from grid for 31 hours. LOOPs are generially 1,2 to less than 4 hours duration.

March 20:

Exelon upgrades equipment at Byron nuclear plant

The Associated Press

BYRON, Ill. -- Exelon Energy says it has finished upgrading equipment at a northern Illinois nuclear plant where a power failure caused a reactor to shut down two months ago.
The company says it has replaced electrical insulators in the switchyards that help move power to and from the reactors at the Byron Generating Station, which is located about 95 miles northwest of Chicago.
In January, an insulator in Unit 2 switchyard failed and interrupted power, causing the reactor to automatically shut down as a precaution.

Insulators are protective equipment that helps regulate the flow of electricity. Exelon says Unit 1 was taken offline last week while upgrades were finished, and Unit 2 upgrades were finished over the weekend. Both units are back online at full power and generating electricity.

Read more here: http://www.bnd.com/2012/03/20/2107206/exelon-upgrades-equipment-at-byron.html#storylink=cpy

Vermont's Appeal over VY

Interesting, the chairman posed the same question I did but in a more delicate manner...
Gregory B. Jaczko: "Looking to the Future”

February 9, 2012

"So the question is: what does that tell us about the use of risk? Is it an effective metric? To some extent one could argue that based on the risk models, accidents like Fukushima will happen -- hopefully with a very unlikely or low frequency, but they will happen -- and they are acceptable. They are well within our risk metrics, primarily because we ultimately had a robust system that allowed people to be evacuated and allowed ultimately for people to be relocated from any exposure to radiation.

Now, I think if I were to talk to an average person on the street and say that, people would say no, that was a pretty significant event. And I personally think that's right. I think that this was a significant event, and it was an unacceptable event. But if we look at the risk models that we use today, it is not -- in our risk model -- an unacceptable event."

Feb 18: I also spoke, "imagine if we had a core meltdown without fatality in a severe accident in the USA. You people discount this, only consider a nuclear fatality. A nuclear accident with fatality is just marginally worst than a no fatality.

At Peach Bottom, it would destroy two plants because they are so close to each other even if the other one wasn't damaged. It would destroy the value of the largest utility in the USA. There would be massive investigations. What was once thought of as accepted behavior would be thought as gross negligence and a cover-up for decades. I am certain the investigation would rip the lid off the NRC and the whole industry...what other plants are threatened. Certainly the NRC losing their credibility and trust would be a accident in itself.

Remember, we have only had a meltdown in the pre internet period and pre social media interconnectivity period. TMI would be a drastically different accident in this social media and self publishing world....nobody could control the political fallout from this. It would cascade until the energy was spent. And Fukushima got us all teed up already....

Who knows what this stock and debt panic would do to the utilities in the outcome in the meltdown without fatality. That is 20% of our electricity, its a enormous amount of electricity and irreplaceable out for a decade or two. We'd have massive speculation, price spikes and shortages for a far as you can see. It would be disruptive to the whole nation. It would be disruptive to our political system. I am talking about a catastrophe of epic proportions for our electric system.

On a planetary level, the USA would be a nuclear technology disgrace...who knows how many plants would get kicked off the line. Our national stature and credibility would be threatened. Depending what they find under the sheets, we might even get a new president...it might just throw the election. You know everyone would play political football with this. Can you imagine the world we would live in if the antis had a current meltdown as ammo?  

Feb 17 (Reuters) - Vermont's Attorney General appealed on Saturday a federal judge's ruling that had prevented the state from shutting down its only nuclear power plant, escalating a two-year battle over state's rights and atomic energy.

Was that pretty neat yesterday in the 2.206 proceeding inviting all the NRC and Exelon employees to watch the Sunday CCN special about the NRC and VY...

Wasn't that neat when i said to them, "does anyone think this is a coincidence that I on am on a phone in my house and I got all you people in your offices listening to me today, and you got a CNN special about Vermont Yankee later this weekend. Does anyone not believe this was intentioned this way?

Then I give them my rendition of the Vermont Yankee problem..."it is excuses over and over again of the NRC and utilities with intentionally turning your heads away from immediately addressing and fixing known problems in the industry"...

NRC’s OIG: Confirmatory Action Letters

Feb 15: Yep, you got to wonder if the NRC OIG initiated the CAL investigation after reading my Casablanca-Palisades 2.206 on Feb 22, 2011... The NRC says the investigation started 9 months ago?

You notice I stayed with the themes of the Casablanca 2.206 on my newest 'Nothing Ever Matters-Palisades' 2.206.     

OIG-12-A-09 February 10, 2012

Audit of NRC’s Use of Confirmatory Action Letters

I think they got a lot of neat tools, but the NRC doesn't have the skills and training in order to properly and effectively use these neat tools. You catch the similarities with the OIG event reporting...mass confusion with contradictory NRC policies. Can you imagine all the confirmatory Actions letters awarded to Palisades and Entergy...and why are they so ineffective with getting a change of heart out of Entergy?  

Jan 10, 2012: Request Emergency Palisades Shutdown

"We are broadly worried about in 2009 over the Palisades security falsification, in the outcome of the violations...whether all the reports and employee cultural surveys with the assortment of NRC and Entergy processes over this very serious violation ever had any meaning at all. According to the Palisades Fukushima Emergency Power System DC short and plant trip, the most recent root cause Entergy admits there is deep and widespread safety cultural problems at the Palisades plant. I feel Palisades safety culture was in the pits in 2009 and before...and the cultural safety survey was a grand Entergy and NRC falsification. The NRC Alternate Dispute Resolution secession over this, the Confirmatory Order, the Entergy investigative reports and safety cultural survey, the willing acceptance of this insanity by the NRC and Entergy...the NRC created the inaccurate falsified impression to the outsiders that Entergy had discovered all the cultural safety problems and corrected them. Nothing could be farther from the truth, all these corporate and agency processes covered up and deepened, took the public’s eyes off fixing Entergy...where Entergy now is in much worst condition than they were then. I request independent outside investigation on this dangerous agency corruption before Palisades start-up."

Audit of NRC's Implementation of 10 CFR Part 21, Reporting of Defects and Noncompliance OIG-11-A-08 March 23, 2011 "NRC Regulations and Guidance for Implementing Section 206 Are Contradictory and Unclear

Part 21 component defect reporting issues exist because NRC regulations and guidance for implementing Section 206 are contradictory and unclear. Specifically, NRC regulations and guidance for implementing Section 206 contain stipulations that have been interpreted as not requiring a report under Part 21 if an LER was not required. This interpretation seemingly contradicts Section 206, which requires reporting of component defects that could cause substantial safety hazards. Furthermore, applicable NRC reportability guidance is not utilized by some licensees and NRC staff, and NRC’s Baseline Inspection Program does not include requirements to inspect licensee reporting of Part 21 defects." Transcripts 2.206 Petition Review Board RE Palisades Nuclear Plant dated January 31, 2012
"And like I said, you know, we can -- all this survey -- cultural survey stuff, you know, words have meaning, and results having meaning and stuff. And that was inaccurate, that survey stuff was inaccurate. And it's a con job because, essentially, Entergy gets to hire their own people. And they probably tell the companies beforehand this is what we want, can you do it for us? And that's what they get.

You know, I don't know. Maybe the NRC ought to hire somebody independent or something like -- I don't know what the question is but, you know, that was -- we could have -- Entergy should have found the problem two years ago and they didn't.

The problem is they go through another ADR process. It began in 2010. It just came out as an enforcement finding with the employee that stormed out of the control room. Basically, the same thing is --another agreement. This thing isn't, you know --Entergy, you do it or stay shut down. This is another-- you know, a gentleman agreement, essentially -- I can't even say the word, confirmaternity [confirmatory action] letter, whatever you call it.
How many (confirmatory action letters) has Entergy had in the last few years --two or three at Palisades, and who knows what they've gotten over the fleet. I mean, how well does that work and stuff? So, you know, so another survey is going to be, done fleet-wide, more fleet training. These poor guys they're getting overwhelmed with all the fleet training on integrity and stuff. You know, it just bothers me that this thing wasn't prevented." US nuclear watchdog questions oversight of safety enforcement

By M. Alex Johnson, msnbc.com

The federal government's nuclear watchdog has faulted the Nuclear Regulatory Commission for failing to follow through on safety agreements with nuclear facilities, saying its system for tracking corrective action raises questions about its oversight of nuclear safety and security.

After an eight-month audit, the NRC's Office of Inspector General concluded last week that the commission has no centralized way to oversee or follow up on documents confirming that a nuclear facility has committed itself to address "significant concerns regarding health and safety, the environment, safeguards or security."

The documents — known as Confirmatory Action Letters, or CALs — are one of the last measures before the NRC cracks down with a stringent binding order like suspension or revocation of a nuclear plant's license.

Because CALs are reserved for a small number of potentially serious cases — 15 to 20 of the hundreds of incident reports the NRC issues each year, according to its records — effective oversight of the confirmation process is of "utmost importance," the inspector general said. But in some cases, the action letters are so poorly drafted that they don't even make it clear who the intended recipients are, the report asserts.

Bureaucracy to blame

The problem is one of red tape, not willful inaction or neglect, the report says. But the weaknesses — which include lack of consistent guidelines for regional NRC offices, regional offices' failure to comply with those guidelines and some offices' lack of any tracking system whatsoever — "degrade" the agency's accountability, it says.

 A spokesman for the NRC said the agency believes "the CAL process has been effective" and that it would have a formal reply "in the near future." In an informal meeting last month, the NRC generally agreed with the inspector general's recommendations to update its main enforcement manual, centralize tracking and submit to occasional audits of the action letter system, the report said.

Peach Bottom SRV Seal notes

Feb 21
Oversight of Nuclear Reactor Suppliers

See, they don't have broadly the proper quality framework to maintain standards...either operating and new.

Like I said, the NRC doesn't have the power or know how to us power and coercion to maintain standards againt the corporate interest of making profits...

Somebody's got to be the bad guy...not a consensus maker?

Feb 17 (Reuters) - Vermont's Attorney General appealed on Saturday a federal judge's ruling that had prevented the state from shutting down its only nuclear power plant, escalating a two-year battle over state's rights and atomic energy.

Was that pretty neat yesterday in the 2.206 proceeding inviting all the NRC and Exelon employees to watch the Sunday CCN special about the NRC and VY...

Wasn't that neat when i said to them, "does anyone think this is a coincidence that I on am on a phone in my house and I got all you people in your offices listening to me today, and you got a CNN special about Vermont Yankee later this weekend. Does anyone not believe this was intentioned this way?

Then I give them my rendition of the Vermont Yankee problem..."it is excuses over and over again of the NRC and utilities with intentionally turning your heads away from immediately addressing and fixing known problems in the industry"...

Main Steam Safety Relief Valves Buna-N thread seals (March17, 2002)

You like that picture, these electrical towers are what the back-up to the back-up Fukushima emergency supply of electricity get supplied to VY through...

First Transcripts

Second TranscriptsSome commonalities with the SRV seals

1) Buna-n.

2) Both facilities when they got new actuators ...during the next cycle their buna-n failed. VY had multiple seal failures after new actuators and Peach Bottom's seal failure came after they were just installed.

3) As a thumb rules, you can't trust the quality of buna-n material after 2002.

Mr Mulligan

I have also spoken with the Peach Bottom Resident Inspectors regarding your request to discuss the Peach Bottom safety relief valve (SRV) seal failure history with them prior to the PRB teleconference. The Senior Resident Inspector, Sam Hansell, and Resident Inspector, Adam Ziedonis, would be happy to speak with you. You can contact them directly at 717-456-7614.

The PRB met internally on February 3, 2012, and denied the request for immediate action to shutdown Peach Bottom Units 2 and 3, and replace the SRV pneumatic actuator threaded seals, because there was no immediate safety concern to the plant, or to the health and safety of the public. Specifically, the PRB determined that threaded seals with Buna-N material have been used in the PBAPS Unit 2 and 3 SRVs for 20 years with no seal failures until the subject failure in September 2011. The 3-ADS-SRV 71B seal had been in service for less than one year before its failure and the seals are replaced every 4 years. In addition, the insulation configuration on the Vermont Yankee SRVs that contributed to their 2 seal failures was confirmed to not be a contributing cause for the PBAPS Unit 3 ADS-SRV 71B failure. These facts support the conclusion that the failure of the 3-ADS-SRV 71B threaded seal was not a common mode failure, or an age related failure, but was isolated to the particular seal installed in the 3-ADS-SRV 71B actuator in November 2010. This information will be included in a future NRC Inspection Report regarding the subject SRV threaded seal failure.

Thank you,

John Hughey

Peach Bottom Project Manager

NRR / Division of Operating Reactor Licensing

Phone: 301-415-3204

e-mail: John.Hughey@nrc.gov

2.206 notes

New 1/31/2012

The big deal out of today is...type 416 ss is cheap metal. All the shafts are made out of 416 ss so why don't they have corrosions like the couplings.

It is shocking to me they are using type 416 on the shafts, as they changed out that material out the couplings...and the NRC and the Entergy never seemed to be worried about the shaft cracking....
Entergy's Root Cause Analysis

January 05, 2012
The three Service Water Pumps (SWPs), P-7A, P-7B, and P-7C, are modified Layne and Bowler pumps. They are comprised of a two stage pump end with stainless steel impellers connected to a discharge head by seven columns for a total height of over 40 feet from suction to discharge.

　
Lucius Pitkin , Inc . Consulting Engineers

METALLURGICAL AND FAILURE ANALYSIS OF
December, 2011
"P-7A and P-7C are Layne and Bowler Model 25RKHC pumps while P-7B is a Johnston Model 25NMC pump. Each pump is driven by a 350 horsepower (HP) motor providing a rated 8000 GPM at 140 ft total developed head (TDH), which is 50% of the service system capacity [1]."

NEW:
From: "Chawla, Mahesh"
To: Michael Mulligan ; Michael J Mulligan
Sent: Tuesday, January 24, 2012 2:45 PM
Subject: Palisades 2.206 Petition dated 1/10/2012 - Mike Mulligan
  

-->

Mr. Mulligan,

I have been assigned as the petition manager for your 2.206 petition which you submitted on January 10, 2012, requesting an emergency shutdown of Palisades Nuclear Plant. Since you submitted this as a 2.206 process requesting an immediate enforcement action, a Petition Review Board (PRB) was immediately formed.

The PRB met internally on January 19, 2012, and denied the request for immediate action because there was no immediate safety concern to plant, or to the health and safety of the public. Your request for the immediate action of shutdown of Palisades and other Entergy Plants did not have the adequate bases. You have cited numerous equipment failures and made accusations of falsification of records and also you find the ROP process to be inadequate. However, you did not provide any additional information for NRC to consider. The staff is well aware of the information you have provided in the petition and these issues/events are being handled by NRC processes.

The 2.206 process is a public process. The NRC normally makes 2.206 petitions publicly available (except for sensitive or security-related material). I believe you are familiar with our process, but please respond to this email and confirm with us by January 27, 2012, that you have no objection to participating in this public process, and allowing your petition to be made public.

Also, the PRB in the Office of Nuclear Reactor Regulation (NRR) will be reviewing your petition. We offer 2 possible meetings with the PRB. One can be before the PRB reviews your petition, in which you or your representatives have the opportunity to provide any relevant information to the PRB. There will be a second opportunity to address the PRB following the PRB’s initial recommendation on whether or not to accept your petition for review. Please advise if you are interested in either one of these possible meetings. The meeting can be in person, at NRC headquarters in Rockville, MD, or by teleconference. These meetings are transcribed, and the transcript becomes part of the record. Please let me know if you wish to participate in either of these possible meetings.

Mahesh Chawla

Project Manager, NRR/DORL

U.S. Nuclear Regulatory Commission

301-415-8371

email: Mahesh.chawla@nrc.gov

 

Entergy in their Root Cause said Palisades had three Layne and Bowler service water pumps. But they really have two of those 350 hp pumps and other is a Johnson model 25NMC pump.

...On the service water coupling, they talk of this repeated wetting and drying cycling that causing IGSSC...the on and off cycling of the pumps. It dries out in the thread crevice, 10ppm which is a really tiny amount of salt . The problem is, the c pump was on 92% of the time while the coupling failed the first time, then 87% of the time the second failure. You know, where is all this opportunity for all this wet/ drying cycling?

They got a little coupling drain hole right in the middle of the coupling. So the water goes in and out this little hole. You know, what the hell does that hole do when the shaft is spinning so fast , then what about all the flow going up the pump. There seems to be a lot of turbulence going on there. So why isn't all this turbulence flushing out all the tons of salt where the shafts meet.

　

　...So i was asking why was hydro-aire trying to "reverse engineer" the modified Layne and Bowlers pumps couplings. I am confused, so the Layne and Bowler pump company hails from the great country of Turkey. Gets you to wonder where all the couplings were manufactured in?
Preliminary report shows Palisades among worst power plants in U.S.

Final report still in the works

"COVERT, Mich. - If a preliminary report by the Nuclear Regulatory Commission is made final, the Palisades Nuclear Power Plant, just north of Berrien County, will be one of the worst performing nuclear power plants in the country.

In 2011, Palisades shut down five times unexpectedly, caused three NRC violations, and required two special federal inspections within a month. “We saw a significant decline in the performance of this plant,” said Viktoria Mitlyng, an NRC spokesperson..."

In the last two months I have spend more time with Viktoria on the phone than I have been with my wife. It is clear she serves the NRC, we had disagreements...but I really like her.

Jan 18, 2012 Detroit Free Press Editorial

On Lake Michigan's shore, no room for lax nuclear safety

"Yet documents and testimony suggest that something as simple as changing a burned indicator light has resulted in cascading events; in the case of the light change last September, the plant ultimately shut down. It was one of at least five unplanned shutdowns in 2011."

It is interesting, anyone who has been watching this knows this sentence is utterly inaccurate. It goes to show, what is a huge factor with what causes a Palisades, is a utterly failed 4th estate.
 

...It is interesting, the Entergy root cause of the emergency airlock not working green light says they were doing trouble shooting (in sept 2011) of the failed light in anticipation of the up coming due surveillance of the airlock. As we know, the light went broke prior to the 2010 Oct outage. One wonders what the surveillance frequency is?  It must have blew past failing other surveillance frequencies and why the sensitivities this time? It is interesting the NRC never covered this issue with the approaching surveillance?

Grand Gulf's new NRC inspection report

"The team conducted a walkdown of the Division II emergency diesel generator room as their inspection. When walking down the perimeter of the diesel generator, the inspectors noted a large puddle of lube oil on the floor on the engine end of the machine near the lube oil filter. The puddle of lube oil contained saturated pads, which had been previously placed to contain the oil. These pads had been overburdened such that oil surrounded the pads.

The team identified that in 2009, a problem identification and resolution team reviewed this leakage on the Division II emergency diesel generator. The team presented a minor violation to the licensee as part of their exit for the licensee's failure to correct the lube oil sump leak on the Division II emergency diesel generator. The licensee entered this condition into their corrective action program as condition report CR-GGN- 2009-06385"...
Electricity declines 50 percent with shale boom

Posted on January 17, 2012 at 6:38 am by Bloomberg in Electricity, Energy demand

(Photo: AEI Services)

A shale-driven glut of natural gas has cut electricity prices for the U.S. power industry by 50 percent and reduced investment in costlier sources of energy.

With abundant new supplies of gas making it the cheapest option for new power generation, the largest U.S. wind-energy producer, NextEra Energy Inc. (NEE), has shelved plans for new U.S. wind projects next year and Exelon Corp. (EXC) called off plans to expand two nuclear plants. Michigan utility CMS Energy Corp. (CMS) canceled a $2 billion coal plant after deciding it wasn’t financially viable in a time of “low natural-gas prices linked to expanded shale-gas supplies,” according to a company statement.

Mirroring the gas market, electricity prices have dropped more than 50 percent on average since 2008, and about 10 percent during the fourth quarter of 2011, according to a Jan. 11 research report by Aneesh Prabhu, a New York-based credit analyst with Standard & Poor’s Financial Services LLC. Prices in the west hub of PJM Interconnection LLC, the largest wholesale market in the U.S., declined to about $39 per megawatt hour by December 2011 from $87 in the first quarter of 2008....

Decline in safety culture at Entergy Palisades nuclear power plant to be fixed

Friday Feb 14 message 2

[QUOTE who="Mike Mulligan"]Hmm, it is not the Detroit Free Press? [/QUOTE]

Wednesday Jan 4 message #7

"What is the difference in a NRC branch manager or project manager?

Did Jack (Jack Giessner NRC Branch chief ) say today Palisades is the worst performing plant in region III or was he saying it was the worst in his group of plant he controlled.

I think he said Palisades is the new worst performing plant in Region III?"

Michigan's Palisades nuclear plant may be named one of nation's 5 worst

The Palisades nuclear power plant, which sits on the shores of Lake Michigan, could soon be downgraded by the Nuclear Regulatory Commission to a status making it among the nation's five worst-performing nuclear plants after a year of accidents, unexpected shutdowns and safety violations.

(...What I was trying to highlight, was when I first mentioned the Detroit Free Press and when the Palisades article first came out of Jan 15th.) 
Transcipt quote from Feb 18, 2010:

"Actually, today is the first day that I have become concerned or fearful of the ramifications that are going around with Entergy and Palisades and Vermont Yankee and stuff."

Palisades Nuclear plant

1) 'Catch-22'  2.206 Petition
Transcripts from my presentation to the Petition Review Board
Feb 18, 2010 
Feb 23
April 9

2) 'Casablanca' 2.206 on Feb 22, 2011
You are chicken e-mail:
March 7, 2011
March 31

3) "Nothing Ever Matters" 2.206 NRC on Jan 10, 2012(tues 9:43pm)

...You are going to have to ask, how close is the design flow capacity of the service water pump to the minimum real tested flow capacity of the pump. Does it impart pump power and amps? What flow affects would happen in the riser if you had to bulk up the 40 foot shaft and the couplings?  Right, making the shaft and coupling larger would reduce the area in the impeller discharge riser and increase the resistance...head. I suspect it is a pumps design trade off with the increase radical area limiting flow to the area needed for the size of the coupling and shaft.

Remember the coupling and shaft sits in the impeller discharge flow.

...Just to show you how freaking sick the system is...the outcome of this is Entergy promised to hire the very same failed third party survey and investigation type company as what failed before. The whole issue of Entergy hiresing these guys and they generally dictates the outcome of the results. It would be better if was the NRC who choose and paid for these services. The whole idea that perpetrator of this preventable decline is the guy who chooses and controls the third party survey and investigator contractor results....it is riddled with blatant self interest.  It is a proven failed strategy in 2008-2009 and the whole lot of them is depending post Jan 11 to do again failure all over again... 

Jan 10 petition

"We are broadly are worried about in 2009 over the Palisades security falsification, in the outcome of the violations...whether all the reports and employee cultural surveys with the assortment of NRC and Entergy processes over this very serious violation ever had any meaning at all. According to the Palisades Fukushima Emergency Power System DC short and plant trip the most recent root cause Entergy admits there is deep and widespread safety cultural problems at the Palisades plant. I feel Palisades safety culture was in the pits in 2009 and before...and the (NRC ADR mandated 2008-2009 )cultural safety survey was a grand Entergy and NRC falsification. The NRC Alternate Dispute Resolution session over this, the Confirmatory Order, the Entergy (third party) investigative reports and safety cultural survey, the willing acceptance of this insanity by the NRC and Entergy...the NRC created the inaccurate falsified impression to the outsiders that Entergy had discovered all the cultural safety problems and corrected them (by 2010). Nothing could be farther from the truth, all these corporate and agency processes covered up and deepened, took the public’s eyes off fixing Entergy...where Entergy now is in much worst condition than they were then. I request independent outside investigation on this dangerous agency corruption before Palisades start-up."

...Further...it is a grave corruption where with these engineering contractor service providers, the employee survey and culture investigation contractors....a company like Entergy will dictate the outcome of the contractor service provider before they are hired the invesigators. The job of the outside third party contractor is to come up or manufacture the plausible facts and evidence to fit the dictates of the corporations defined before even the investigation begins. It is the filler material before the artificial results of the so called and independent third party investigation.

That is why they fail over and over to change the results of the nuclear plant behavior like Palisades...

They are all great gamers! 

Jan 10, 2012: Request Emergency Palisades Shutdown

New Jan 27

We have arranged a PRB teleconference for January 31, 2012, from 1.00 pm to 2.00 pm EDT. During this conference, you will have approximately 45 minutes to provide any additional information regarding this petition. Please confirm your availability. Thanks

Jan 10, 2012

R. William Borchardt
Executive Director for Operations
US Nuclear Regulatory Commission
Washington, DC 20555-0001

　

　

Dear Mr. Borchardt,

The Poppersville Town Hall

Request Emergency Palisades Shutdown

What are we, on the sixth or seventh shutdown within a year, certainly five plant trips. Does all these trips and shutdowns caused fuel damage? This is how I began my Feb 22, 2011 2.206:

“Subject 2.206: Request a emergency shutdown of Palisades because the Reactor Oversight Program is ineffective and Entergy has a documented history of a culture of falsification and thumbing their noses at reoccurring violations. It should be noted in this inspection period most of the fleet of Entergy’s plants are on fire and burning in the Gulf of Mexico with numerous NRC inspection findings including Grand Gulf, River Bend, Arkansas One and Cooper.
Jan18, 2011: My 2.206 Emergency Shutdown of Vermont Yankee
“The safety culture of the plant is impaired because of information inaccuracies and wide spread acceptance of falsifications.”

“I request Vermont Yankee to be immediately be shut down and that Entergy be prohibited from owning nuclear power plants... because Entergy doesn’t have the integrity to tell the truth about safety and nuclear power plant issues. Money and profits comes before truth telling and full disclosures.””

Did you like this from Feb 22, 2011?

In the 1942 movie Casablanca:
Rick Blaine: How can you close me up? On what grounds?
Captain Louis Renault: I'm shocked, shocked to find that gambling is going on in here.”

Here is some quotes from the old Feb 22, 2011 2.206?

“The CRDM seal leak and other repetitive problems drive organization into cycles of dysfunction and disorder.”
“We worry Palisades will steal NRC resources from finding problems at another plant.”
“There is another concern, in that that it is cheaper for the Entergy to make the NRC provide contract engineering and safety services than with Entergy doing it with their own staff.”
“It would know the conditions (dysfunction) of the managers and employees, we would know every error of a policy, the absence of a procedure, rule or organization attribute, know perfectly every defect in every component. We would have the perfect god’s eye view of the plant and the organization. Push the magic button, do we have a green, yellow or red light at Palisades, the NRC or Entergy?”
“Palisades has a documented history of past serious problems, I think the NRC is overwhelmed so we are only seeing a small percentage of the problems at the Palisade plant.”
“We know from the study of the past that there are huge problems spinning unseen right now at Palisades that the NRC doesn’t document. It is going to boggle the mine with what the NRC discovers in the next year or two at Palisades, just like the last two year. I say they are going to find bigger and more repetitive problems.”
“It seems they’d rather keep the agency busy on games with old problems so they wouldn’t find new dangerous problems.” (AFP trip throttle vlv spurious trip)
“Don’t you wish you have the button on your computer where it would give you a yellow, red or green light? How are we doing right now? How will the whole of Entergy do in a year, two or five years...where will the NRC be stationed in the next decade?”

“History teaches us unimaginable things are going on behind the security fence of Palisades, and the NRC misses the really important stuff. Better, the NRC doesn’t have the power to make Entergy meet the greater ends of us all...”
“You going to see this over and over again when a device fails and threaten a shutdown Entergy goes intelligently stupid. A lot of short term profits can be made by faking stupidity...it steals long term security from the whole of all of us. They automatically declare, to maintain capacity factor numbers without technical foundation, it is not safety related.”
“This is all a game and its disconnected from ethics and morality.”
“I think the biggest risk is not from the threat of a bad accident from the direct engineering falsification of the component, but the threat comes from killing the spirit of their employees.”
“We knew the UFSAR was so simple minded and lacking of any real information, we called them our comic books.”
...“We worry if the NRC is participating in some kind of malicious, malignant or narcissistic compliance issues over regulations with congress, a narcissistic technical ideology that is destroying the industry. Basically self interested ideology and technical propaganda overrides the facts.”
“You get it, the spinning component, engineering and organizational problems in the ether of history past and future. The reoccurring capacity factor issue with the unreliable leaking CRDM seals and many plant shutdowns over them.”
“It is absolutely mind boggling on a nation level how these plants don’t learn from each other...the reoccurring problems on a national level.”
...“This is atrocious behavior by the NRC because they are telegraphing to the licensees, before we force you to shut down because of inadequate assurance for safety, you are suppose to lie to us. You are allowed to lie to us without fear of penalty. You can admit to your lie months later after the operational threat and you will be forgiven from any falsification. Remember, if you fail to lie to us we will be force to place you in safe condition and shut you down. Falsification is a state of business in the nuclear industry and you better learn how to do it good!”
“Entergy has the pattern of internally sabotaging and disabling their safety and oversight authorities in order to boost capacity factor and profits. It is part of their business ideological plan to thumb their nose at standards in order to push capacity factor and stock price.”
“How come there is no talk with the NRC that our oversight activities have absolutely no affect over Entergy and Palisades?”
“God help us all, can you see the problem with the repetitive nature of Entergy having the instincts to not the due proper inspections...to do it over and over again like a madman. They are laughing at us and the NRC because these employees and managers know we can’t control them. The NRC has no ability to control Palisades...that is my god damned political statement to the NRC.”
“This thing has become a voluntary compliance and code thing...we have absolutely privatized nuclear power plant engineering safety compliance into a corporatism code authority.”
“It is almost like you are entering non USA territory when coming onto nuclear plant property. It is as if the corporate property is exempt from USA regulations and the governmental authority.”
“Are all you people idiots in Michigan? You too hard up for telling truth because of low employment and economic problems.”
“It is just a business objective with Entergy to try and squeak as much work as the can under the proper codes, rules and professional employment qualification as they can. FASTER, CHEAPER, BETTER:...survival only with high capacity, it is just a business ideological tenet. It is lying and falsification to make profits as a acceptable business strategy or model for both Entergy and the NRC! It is lying and falsification in order to gain societal status and rewards...it is not about making our lives better.”
“Managers in maintenance organizations did not have a detailed understanding of QC responsibilities, required inspections, or what documents required review (CR HQN-2009-01150).” (No shit, the DC short)
“This is nothing about the NRC fulfillment of their procedures or rules. Procedures and rules have no soul and spirit, just like a machine. They got to be doing this for a higher reason. Increasingly the NRC thinks their rules and regulations are the primary objective of what they do. It gets down to malicious compliance with congressional intent. It knowing compliance with legislative intent is going to drive our nation over a cliff. The intent of regulations is greater safety and that the utilities are in service to our nation. It gets down to NRC malignant and narcissistic compliance to legislative intent. It is what they have to do to go home and enjoy their children and families. It turning providing for your families on its head...it is altruism abuse and disorder of the highest order. It has become such a horrendously narrow pathway...it is no doubt our politics are driving this narrow mind set.”
“If we magically knew everything though a push of a button of all the sins of Entergy, had a perfect image...then there would be an incentive or punishment to fit the condition driven from all we know. The objective of it all is to make a better world for ourselves.”
“Doesn’t that bother you people, we don’t have at our fingertips the ability to know if all the safety equipment meets the codes and Entergy is a fully healthy nuclear utility. The things that are in the temporal dimension...in time...we don’t get a image that helps us see the real sequence and magnitude of all the defects. It doesn’t help us to make Entergy better.”
“Them comic book UFSARS again?”
“The NRC reduced last inspection period a threat to plant operation and capacity factor by falsifying the term, we test the hardness of every coupling while trying to get a enforcement discretion. So it is closed. It is acceptable for a utility and a vender to lie to the agency if plant operation is threaten? Just where do you go for in NRC, on what is the right way for you to lie the NRC? Is it in the inspection manual or reg guide?
“This the biggest philosophical question out of all of this is; does following the rules, policies, codes and procedures get us to the outcome we want? Will following the rules bring us all back home safety and soundly? Is following the rules the ends, or is there some higher calling or order we should direct our heart and heads towards?”

Feb 22, 2011:

“Based on the above, to date the NRC’s Reactor Oversight Program and the inspection activities in the plant has demonstrated the inability of the NRC to change the heart of Entergy. The NRC has expended enormous resources in confronting the Palisade staff...but the situation is only getting worst. In just a few inspection reports we get to see the repetitive nature of the violations, such a the polar crane issue and the VT-2 visually reactor inspection problems. There is the sense Entergy across the board is toying with the agency...trying to exhaust the capabilities of local inspectors with a assortment of bureaucratic games.”
　
You think this cheapskatism and local contempt to the community is limited to Palisades and Vermont Yankee. You can see the beginning of this corporate business philosophy rummaging thought Vermont in 2007 and crashing into Michigan through 2011. I going to tell you something about Entergy’s reform affords across many years and many states. They are really good at talking and giving pretty wordy side show presentations that are eye catching. It is going to take firing of Entergy executives really high up to change this. But their history is they don’t mean a thing in talking to the public. The only thing that matters for these cold hearted people is the $2 million dollar they collect every day for a plant to be connected to a grid. The pattern is they will lie though their teeth in the presentation to get to their $2 million dollars a day jackpot tomorrow. (Jan 11, 2012 DC plant trip and service water NRC presentation)
GMP, CVPS file lawsuit against VY over tower collapse

BRATTLEBORO - Vermont's two largest utility distributors have filed a lawsuit against Vermont Yankee's parent company, Entergy, in Vermont Superior Court in Windham County.
Green Mountain Power and Central Vermont Public Service have filed a joint lawsuit over costs resulting from the plant's failed cooling tower in 2007 and 2008.
"This case arises out of Entergy's breach of its contractual obligation to us 'Good Utility Practice' in its management and operation of the Vermont Yankee Nuclear Station," the companies stated in a joint statement this morning.
Palisades and Entergy Engineering Philosophy

With the service water coupling, first it was the heat treatment and then intergrannular stress corrosion cracking and hardening...you tailor your engineering judgment into the smallest consequence to the plant outcome independent of the real factor. How often does Entergy do this, tailor a engineering judgment to limit short tern economic damage to its stock price instead of confronting the real problem?

Service Water Coupling

So from impeller to motor it is 40 feet...you got some 40 odd feet of pump shaft. I tell you what, the couplings and the pumps shaft looks pretty small for the pump capacity and its length. As far as I know, you got 6 nylon or rubber bushing that radically support the extremely long pump shaft between motor and impeller.

So the furthest couplings from the impellers failed....the 5 and 6 coupling. I been reading coupling failures with IGSCC that have been out of water and dry for many years and in standby. Palisades use these guys much more that...the wetting and drying corrosion theory. I don’t buy the wetting and drying IGSCC are applicable.

You should be worried why only the closest to the motor couplings have failed? According to the NRC:

2006 – INPO Operating Experience Digest 2006-02 – INPO released a document that discusses SW pump (shaft, coupling and impeller) failures occurring in the industry. The report noted that 12 failures occurred between 1998 and 2006, with the most frequent including corrosion causing coupling separation. One of the common causes identified was improper heat treatment of the material during manufacturing; and

February 9, 2007 – NRC Information Notice 2007-05, “Vertical Deep Draft Pump Shaft and Coupling Failures,” was issued and referenced the coupling failures from IGSCC that occurred at Columbia Generating Station. The couplings were 410 Martensitic SS and were susceptible to tempering embrittlement. The operating experience review identified at least 23 essential SW pump shaft and coupling failures since 1983 involving more than six different manufacturers.

I have zero faith, especially with the voluntary INPO and other private data bases that all the coupling failures and near misses are documented. There is supposed to be punishment if they don’t report to the government instead of this wholly voluntary groups paid by the nuclear utilities. So we got 35 failure and some might be double counted. A data fanatic would be sick that a true count wasn’t available and a detailed written evaluation of each. I know at other plants some of the coupling failure have occurred near the motor. One wonders how many of the coupling failures industry wide are near the top. It goes to show you how shallow this Palisades coupling investigation is.

What is also missing, a discussion on the condition of the impeller intake screen and the conditions of the impeller. Are there indications of sand or intrusion damage on these components?

It is common sense with the motor the stand-still inertia with the two SS impellers and all the seven lengths of shafts and the couplings themselves fights the motor start-up. With the huge 40 foot length and the weight of all the components, I think the top of the narrow shaft bows and wobbles, and the shafts and the couplings torsions and twist. When the pumps are started, the whole shaft and couplings get tensioned. Its electric motor starting causes elastic and inelastic repeated deformation of exspecailly the upper shafts and couplings. The upper area of the shaft near the motor carry's all the stand still inertia of the components. This creates enormous stress in the fragile upper coupling leading to micro cracks on the surface of the couplings. This then allows IGSCC to set in. I would like to see the startup and shutdown record on all the pumps...is there an association? I suspect demanding large capacity increases of water cause the same thing. I’d like to know what the resonance and harmonic frequencies are in the upper area. You got to know a pump and motor with the shortest shaft distance between the pump and impeller is the safest.

If these Energy and the NRC were professional they would have set up a mockup of the service water pumps and then taken all the data and parameters they needed. Instrument up everything!

What the heck is “bumping the pump”, and how many times do they do it? ” Does everyone else do it?
Root Cause Evaluation Report
Service Water Pump 7-C Line Shaft Coupling Failure
CR-PLP-2011-03902, EVENT DATE: 08-09-2011
Based on the FEA analysis, the in situ tensile stresses and a description of the actions taken to "snug" the shafts during installation, it was determined that Palisades practice of "bumping" the pump to tighten the shafts was not a likely contributor to the failures in September 2009 and August 2011.

You would think you’d want these coupling torqued with a good torque wrench. This is a nuclear power plant but sounds like a broke and low paid employee paper mill. How much torque does it take to unscrew a bumped coupling...what is the quality of a accurate torque with a nuclear service water safety pump? Can’t you see them starting the pumps up on a loose coupling, the motor immediately gains a lot of speed without the inertia of the heavy metal below it...the impeller stays still for a fraction of a second. Then bang, the coupling runs out of threads and finally overcomes inertia...with the coupling over tightened. You would think the coupling and the shafts would become more structurally stronger and larger depending on how much inertia and rotational weight they carried going up the length of shaft towards the motor? They look all the same size to me?

I think with the bushings the long shaft wobbles...again deformation with the coupling and shaft, and leads to stresses and IGSCC.

The Palisades service water pumps are defective. The shafts, couplings and their threads are way undersized, the shafts too long for the duty they are undergoing. I wonder nation wide what are the lengths of the service water motor to impellor length...are there any damage or maintenance issues with a pump and impeller shaft being too long? Is the Palisades service water pump and impeller shaft longer than most of the other plants. Again, any association with troubles with shaft length. The Palisades service water pumps are defective and dangerous. I request that the Palisades plant remain shutdown or shutdown until new service water pumps are installed.

Finally, we need to talk about the standards of certainty I need and then what the NRC finds acceptable from Entergy. As a outsider whistleblower, I need impossible to get absolute and triplicate evidence and proof about a concern I have. Even in safety related discussions, the standard of engineering certainty in the nuclear industry is “not a likely contributor”. Why the difference for the NRC with uncertainty, weasely words and standards between me and a nuclear plant engineer? I bet you the lawyers love that get out of jail word definition. Anyone got a list of engineering and NRC definitions... what the hell does “a likely” mean?

...It was determined that Palisades practice of "bumping" the pump to tighten the shafts was not a likely contributor to the failures in September 2009 and August 2011.

Emergence of Systemic Meltdown of Entergy

Yesterday, the NRC disclosed a $140, 000 fine for River Bend with the “at the controls” licensed plant control room operator’s knowingly violating procedures and going on the internet at a nuclear power plant. What really displeased the NRC was the failure of Entergy to fully investigate the incidences and correct it. Recently the NRC disclosed a licensed operator stormed out of the Palisades control room of the plant over a conflict with other employees without notifying his management. By the way, the NRC and Entergy never discusses if employee/management relations are ruptured. What really caused employee conflicts that almost ended up as violence in the control room of a nuclear power plant?

Gets me to wondering if the widespread employee culture survey coming out of the Palisades security falsification was accurate and a falsification on top of another falsification.

From River Bend, don’t forget River Bend’s issue with QA/QC national issues and intimidating a engineer over a safety related concern, to Pilgrim’s start up overpower trip by not following procedures and control room distractions during the starup, and the horrid repeated problems with Palisades shutdowns, trips, down powers and special investigating...Entergy fleet nation wide has had a tremendous amount of fleet training about doing the right thing and following procedures in the last year and nothing works. All that fleet training about doing the right thing and following procedures was for nothing and it is getting worst.

I need to make a comment about corporate, personal and individual privacy issues. A lot of these investigation...the resultant media attention, punishments and corrections have been delayed for years over privacy issues. The rights of culprit who don’t follow procedures, those who lie and cheat, the rights of those who knowingly don’t follow procedures or have crappy procedures take precedence over the rights of a community to have a orderly and well behaved plant. We know the NRC and nuclear industry are using privacy issue...the ADR process...using privacy issues to massively delay and dilute plant accountability and individual punishment..to create unnecessary secrecy. Delayed Justice and Justice behind closed doors to the community around a nuclear plant is no justice at all. Why doesn’t a community's rights of knowing what is going on come first instead of a miscreants won’t follow codes of conduct, procedures and rules?

I don’t think coming into the nuclear industry gives them a total refuge of no public or personal accountability and all their sins will remain hidden. I think all nuclear employs should dedicate their live too transparacy and openness...and their personal lives and especially their at work lives should be scrutinizes more that everyone else’s. This fixation with employee privacy issues exspecailly by the NRC is allowing these nuclear facilities to get away with murder. Can’t you hear all these NRC officials, we all disserve special privacy issues because we get the big bucks and its our special privilege to be different than anyone else and to be protected more than the pitiful normal poor people.

　

Massive backlog of procedure up dates, plant maintenance and technical updates

Entergy Fukushima DC power Plant Trip Root Cause dated 11/17/2011:
...“Prior to the 2010 refueling outage 1R21, routine preventive maintenance performed per work order WO52025543-01 identified that the green status indication lights for the containment escape air lock MZ-50 were not working. Although CR-PLP-2010-3580 and work request WR210717 were issued at the time, this condition was not addressed until the troubleshooting activities scheduled for Thursday 09/22/11 under WO248834-01.”
... “During this coordination meeting it was determined that mechanical work associated with Containment Escape Hatch MZ-50 would be scheduled for early Monday 09/26/11.”

Man, what kind backlog of maintenance do they have, where they have this inoperative green light powered from the DC emergency power system prior to the Oct 2010. They are talking about a year before they discover it was broken and repairing it. Is this the competency and excellence you would expect out of a great nuclear plant and nuclear organization. This maintenance delay of a year, the computer processes that creates it, or hid it from repair, or not enough Entergy resouces to get maintenance done in a timely and safe shutdown manner. The organizational chaos and blindness of a year or more that created or triggered the long journey towards the DC emergency power system short and plant trip. I don’t see anything about this in tomorrow's Entergy’s presentation and the whole of Entergy’s root cause analysis or the prior NRC inspection activities.

They don’t begin to trouble shoot it until Sept 2011 and how many shutdown have they had to fix it. Their work prioritization system is all screwed up and everyone knows it...can’t distinguish between a safety system and everything else. I bet you they got so many backed up work orders it buries their document system. Bet you if they documented the escapee hatch light as "you can’t startup" if it is not fixed, it would have been fixed right away or decades ago? Didn’t they have issues in the past with the airlock mechanism jamming and almost killing employees? It is kind of evasive where they speak in “prior to 2010”, how much prior to Oct 2010?

As a note, it looks like the DC panel wasn’t designed to be entered with a energized panel, and especially up at power. How many more panels and components do they do major work on when they are energized and up a power, that is specifically not designed for this kind of work. A properly designed panel would be a lot more spacious for the breakers and bus work inside. The side, back and front outside panels would be completely removable. Access to all components would be easy. The panel would be in the open on all sides. It would have plenty of distance from other obstructions and panels where people could gain easy access to all sides. There are doing stuff on these components that it wasn’t designed for or thought of in the beginning. That is a grave engineering sin.

Disgusting, an abandonment by senior management to good employees. They fired a license operator for leaving the plant without permission...so when are these senior managers going to get fired for doing worst? I get it, fired the little guys and make a big deal over their sins. But the big senior managers who make the really big bucks and got the power to know and correct problems always get a free ride. You know, senior nuclear plant managers and senior NRC officials got to sick together in their little Glee Club?


“Senior leaders do not consistently exhibit a bias for action when addressing organizational issues. For example, senior leaders had seen indications of weakness in managers’ support of the duty team during the forced outage earlier in the month, but they did not take action to ensure that the necessary levels of support were provided over the weekend of the event.”

Generic Implications - Extent of Condition/Extent of Cause

A review of Maintenance Emergency Power System procedures found that, even though these procedures have been in use, six of the twelve current procedures have not been revised since 2007 when the plant was part of NMC. With respect to this situation, the more current DC breaker procedure EPS-E-12 includes requirements for breaker bolt torquing and the use the EN-IS-125 electrical safety checklist. Corrective actions have been assigned to review and revise these procedures.
Currently, more than 400 change requests exist for the Permanent Maintenance procedures. Based on the number of severely outdated EPS system procedures, the status of Maintenance procedures for other systems could also be at risk.
This has been affected by the willingness of Maintenance workers, as in this case, to continue to use inadequate work instructions. Corrective actions are assigned to identify and correct these procedures and to establish a method for regular update review.

I mean, come on, Fukushima Daiichi Emergency Power System procedures. I’d like to ask the question if the other DC side failed when this trip happened and no DC? With the plant and Entergy bungling over so many issues in the last few years...to me it is highly plausible the other side might have had a defect it in. Over all NRC inspection reports in the last year and all the issues discovered so far by Entergy this year...can you even imagine all the bad procedures, missing maintenance and senior management inattention. Can you imagine the Fukushima chaos and disorder they would have had at the plant if they had a total loss of DC accident or similar accident in this past Sept. Anyone can operate a power plant at power with no problems, but it is a completely different world when the plant goes to shit.

I request the Palisades plant remain shutdown or the NRC shuts them down. I request all Fukushima Emergency Power System (EPS) procedures, all other plant procedures of all kinds and all backlogged maintenance be fully completed before start-up. All technical updates what so ever be completed. I request all training and schooling for any employees become completely updated.


The Nuclear Regularly Commission

I consider the recent events of the four NRC commissioners and headhunting of chairman Jazcko as a severe intimidation to all the NRC employees and all the employees in the nuclear industry. I think a lot of the employees think the nuclear industry can buy the four NRC commissioners to go head hunting for the chairman who is perceived to be coming from the democrat side of the aisle. If you are not in our group, the regular boys know the executives and officials we can lop off any head. I think all the employees in the industry fear the penny profit and highly paid bonus centric mongrels at the head of the nuclear and electric industry. I requested a independent wide survey of NRC employee’s feelings about trying to take out the chairman, and throughout the industry.... about the head hunting in the NRC commissioners office that has recently occurred. Is anyone in the industry intimidated about raising safety and what do the professionals think about this? The region III PR people don’t seem to be interested in this. They are too chicken to bring up my issue to the Washington DC NRC.

I consider recent events at Browns Ferry post red finding, at Entergy and post accident...all recent event investigation at a lot of plants in the nuclear industry as very disturbing and troubling. A tremendous amount of NRC violations and engineering safety shortcomings are discoverers through playing the gambling slot machine of a accident or a surprising unexpected operation or mis-operation of a safety component, person group or organizational. Why isn’t Reactor Oversight Program catching these violations and engineering shortcoming...why isn’t the ROP picking these up and making a plant or nuclear corporation become a good citizen? Why isn't it rare that we never get a severe plant accident or employee screw–up without a slew of NRC findings with secret hidden violation, some for decades. Why no clean accident or event without secret hidden violations? I believe if a organization seen all their secret unseen violation through a comprehensive NRC inspection, it would make a plant like Palisades, River Bend and Vermont Yankee a better corporate citizen.

I am telling you, we got a runaway petroleum well in another Gulf of Mexico and it riddled with weak regulation and government oversight ….massive secret non disclosed violations and really poor safety engineering! I believe the NRC are in agreement with these plants, in that large numbers of secret violations don’t matter. I estimate that only a third to a half of all NRC and corporate violations are discovered in a timely manner and reported in a inspection report...not uncovered in the worthless Reactor Oversight Process.

If the NRC and a nuclear company has a agreement that certain violations can remain secret...you then need a enforcement system and enforcer employees who make good employees keep secrets from the public. Secret accepted NRC violations without full public disclosures are a gave threat to the culture of the NRC and any nuclear plant safety culture. Great nuclear secret violations enforcer employees are usually poor safety employee…while good safety employees usually get poor employee evaluation in this system. Guess who gets promoted to the big bucks?

NRC Special Inspection On The Fukushima Emergency Power system

This is symbolic of the do-nothing and nothing-ever-matters risk regulation NRC. They cleave to the safety of always writing a report after a serious event  but never have the guts preemptively stop a accident. The life of a licensed operator up in these nuclear control rooms depends on them sizing up the conditions around them and acting correctly on fragmentary and not complete information at a moments notice. The most important things up there is judgment to preemptively act on emerging problems before they get big. Think about it, if the NRC inspectors were in a control room of a domestic nuclear plant… and the corporation and employees were brazenly acting crazy threatening an impending core meltdown…would the inspectors have the stones to demand a stop work order or request a immediate scram of a plant? I know the government officials would be thinking the safe thing to do is write a report once the nuclear cloud dust settles. They can never fault me for writing a report.

The NRC should have been extremely intrusive with watching over this DC Emergency Power System incident. The agency is as bad as the Palisades root cause team on identifying the lack of enthusiasm with senior Palisades managers. The NRC resident inspectors should have gotten word and keeping up to date with the EPS travails leading up to the erratic control room indications two days before the DC short. Two days before the Emergency Power System short and plant trip, the inspectors should have demanded an immediate stop work order and required a immediate scam on the first Fukushima Emergency Power system short.. Certainly when word of the arc marks on the bus work became known...that should have tripped the NRC into immediate action. When was the last time you ever heard the NRC demand a immediate stop work order or demand a plant trip? These guys are too chicken to do their jobs. The NRC should have known the Palisades senior manager didn’t have their stuff in the right sock, they were confused and missing in action...the NRC should have without the erratic control room instrumentation indication and arc mark on the bus work, should have demanded a stop work order based on the Entergy system being in a state of incompetency.

We pay these officials big bucks and they say in surveys the NRC gives them a happy work inviroment at the agency...we should demand these officials be very intrusive at a troubled plant and never have any fear with jumping in the arena of demanding a stop work or plant safety scram.

This NRC’s Sept 23, 2011 in real time failure to “perceive organizational dysfunction” and then “failure to act” on a grossly unsafe repair of a Emergency Power System is a grave symbol of NRC as a whole, that collectively the agency is too systemically weak and fearful to preemptively “step into a plant” and force a plant into being safe.

The NRC is there to take the punch bowl away from a drunk, blind and chaotic staff of any nuclear power plant that threatens our nation and the nuclear industry.

"These electrical losses resulted in a reactor and turbine trip at approximately 3:06 p.m. on September 25, 2011"....

page 22:

Description: On Friday, September 23, 2011, the licensee performed troubleshooting and replacement of DC Breaker 72-123 on Panel D11-2 due to the loss of indication lights for Door MZ-50, the emergency airlock. During maintenance restoration of the FME barrier for Panel D11-2 (a metal strip down the center of the panel), control room alarms were received for the TG voltage regulator, generator over-excitation, and a loss of indication for multiple containment isolation valves. In addition, a loss of normal instrument air was experienced in the plant. Troubleshooting performed by electricians Friday night and early Saturday morning identified a 1/16-inch gap between the Panel D11-2 positive horizontal bus stab and the contacts on Breaker 72-119, which could cause the intermittent power loss to the breakers in Panel D11-2

                                                  Fed 22, 2011

“It would know the conditions (dysfunction) of the managers and employees, we would know every error of a policy, the absence of a procedure, rule or organization attribute, know perfectly every defect in every component. We would have the perfect god’s eye view of the plant and the organizations. Push the magic button, do we have a green, yellow or red light at Palisades, the NRC or Entergy?”

Jan 10, 2012

Request Palisades nuclear power plant and all Entergy nuclear power plants be immediately shutdown.
1) Request top Palisades Management staff be fired and replaced before startup.
2) Request Entergy’s corporate nuclear senior staff be fired and replaced before the restart of the plants.
3) Immediately request two addition NRC inspectors to be assigned to Palisades plant, and to all the rest of the troubled Entergy nuclear plants. There seems to be a few plants of the bunch that behave themselves.
4) Request the formation of a local public oversight panel around every plant.
5) Request a emergency NRC senior official oversight panel with the aims of reforming the ROP.
6) Request a national NRC oversight panel of outsiders to oversee and report on the agency’s activities. There should be a mixture of professional academic people and capable lay people.
7) There is some heavy duty and exceedingly numerous findings of problems with Entergy plants’ this inspection reporting cycle...do an analysis of why this is occurring.
8) Request a evaluation if NRC region III has enough personnel and resources.
9) Request Palisades to stay shutdown or remain shutdown until the replacement of the three service water pumps.
10) Stay shutdown or remain shutdown until all procedures are fully updated and corrected, all technical and maintenances backlogs are updated and corrected, all training completed, all reports and safety processes fully completed and implemented.
11) Request a report by the NRC on why the region III NRC failed to stop work and demand a reactor scram of Palisades prior to the electrical short and plant trip with the DC “emergency power system”.
12) Doesn’t it drive you data driven nuts crazy...the system doesn’t force all the utilities to report all coupling failures, degradations and near misses. Request the NRC fix this problem!
13) I request that President Obama fire Chairman Jazcko and the other Four Horsemen of the Apocalypse Commissioners!
14) Request a independent outside investigation over the insufficient process outcome of the 2008-2009 Palisades security falsification, investigation, safety survey local and fleet wide training and safety surveys. Based on the DC root cause it appears the safety culture for many years has been grossly defective and ineffective, along with the ROP...with then all these processes failing to discover the true depth of Entergy’s safety cultural problems and they lied about these processes fixing Entergy. It sounds like this is a generic problem to me.
We are broadly are worried about in 2009 over the Palisades security falsification, in the outcome of the violations...whether all the reports and employee cultural surveys with the assortment of NRC and Entergy processes over this very serious violation ever had any meaning at all. According to the Palisades Fukushima Emergency Power System DC short and plant trip the most recent root cause Entergy admits there is deep and widespread safety cultural problems at the Palisades plant. I feel Palisdades safety culture was in the pits in 2009 and before...and the cultural safety survey was a grand Entergy and NRC falsification. The NRC Alternate Dispute Resolution secession over this, the Confirmatory Order, the Entergy investigative reports and safety cultural survey, the willing acceptance of this insanity by the NRC and Entergy...the NRC created the inaccurate falsified impression to the outsiders that Entergy had discovered all the cultural safety problems and corrected them. Nothing could be farther from the truth, all these corporate and agency processes covered up and deepened, took the public’s eyes off fixing Entergy...where Entergy now is in much worst condition than they were then. I request independent outside investigation on this dangerous agency corruption before Palisades start-up.



Sincerely,

　

　

　

Mike Mulligan

Hinsdale, NH 03451

steamshovel2002@yahoo.com

1-603-336-8320

　

　

　

　

　

　

　

　

　

　

　

　

　

　

　

　

　

　

　



　

Posted: 01/10/2012 10:50:47 AM EST

Updated: 01/10/2012 10:57:20 AM EST