Escalation of problems with Peach Bottom’s SRVs

Originally published on Nov 15, 2012

Nov 26: Doing a little work on this for a few days...

Nov 25: How come from a period of 8/01/2001 to 11/25/2003(8) compared to 8/01/2009 to 11/25/2011(23) there are 300% more BWR's safety relief valve license event reports from the same length of time.I did a search on these terms in NRC Adams document system... 

The two year period covers the typical 28 months to two year operating cycle....

Content search on "Safety Relief valve" and "LER". 

Do you think the NRC criteria for writing LER had loosened, tightened or stayed the same. I think it loosened.

Why are there more troubles today?  

Nov 18: LER2012001

"There were no previous similar LERs identified involving an ADS SRV inoperability due to failure of the actuator diaphragm thread seal."

Well, truth be told, in the 2003 dual plant trip with SRV failures, with the SRV pilot valve stem packing failure on the steam side, the steam leak from the main valve damaged the actuator diaphragm thread seal and the heated steam damaged the diaphragm preventing opening the valve by control room switch.

...Hmmm: "The six SRVs and the one SV were replaced with refurbished SRVs / SV for the 20th Unit 2 operating cycle."

"There were a total of seven SRVs and one SV initially removed for testing and replacement during the 1 9 th Refueling Outage."

So 6 out of 7 were failures...so a 86% failure rate...430% more failure than average... 

So this outage had 500% more SRV failures than expected and the alarms bells hadn't gone off? Licensee Event Report (LER) 3-07-01: 

(2007)A historical review of SRV as-found test set points indicates that approximately20% of valves tested over time do not meet the + 1% Technical Specification set point.

Unit 2  LER 2012001 event date 9/26/2012

Based on information received from a laboratory performing Safety Relief Valve (SRV) / Safety Valve (SV) as-found testing, Site Engineering personnel determined on 9/25/12 that SRV / SV setpoint deficiencies existed with six SRVs and one SV that were in place during the Unit 2 19th operating cycle. The SRVs / SV were determined to have their as-found setpoints outside of the Technical Specification allowable ± 1% tolerance. The six SRVs outside of their Technical Specification (TS) allowable setpoint range were within the ASME Code allowable ± 3% tolerance. The one SV outside of its TS allowable setpoint range also exceeded the ASME Code allowable ± 3% tolerance. The cause of the SRVs / SV being outside of their allowable as-found setpoints is due to setpoint 

SRV 71A 24 1143-1167 1121 -2.94%

SRV 71D 16 1124-1146 1118 -1.50%

SRV 71E 81 1124-1146 1103 -2.82%

SRV 71F 19 1124-1146 1116 -1.67%

SRV 71G 82 1134-1156 1127 -1.57%

SRV 71H 17 1134-1156 1111 -2.97%

SV 70B BL-1095 1247 - 1273 1303 +3.41%

10CFR 50.73(a)(2)(i)(B) - Condition Prohibited by Technical Specifications 'Technical Specification Limiting Condition for Operation (LCO) 3.4.3 requires that 11 of the 13 SRVs / SVs be operable during operational Modes 1, 2, and 3. Contrary to this requirement, six SRVs and one SV were found with setpoints outside of the Technical Specification setpoint requirements.

10CFR 50.73(a)(2)(vii) - Common Cause Failure of Multiple Trains being Inoperable - Six SRVs and one SV were considered inoperable as a result of exceeding their allowable setpoint range based on laboratory testing. Therefore, this occurrence is considered as a common cause failure of multiple independent trains being inoperable.

There were a total of seven SRVs and one SV initially removed for testing and replacement during the 19^th  Refueling Outage.

 That is a 100% failure rate and they don’t test all the rest of them...???

LER 2-10-03 reported two SRVs and one SV having their as-found setpoints in excess of the TS allowable + 1% tolerance. LER 3-07-01 reported two SRVs and one SV having their as-found setpoints in excess of the TS allowable ± 1% tolerance. LER 2-06-02 reported one SV having its as-found setpoints in excess of the TS allowable ± 1% tolerance. LER 3-05-04 reported a situation involving four SRVs having their as-found setpoints in excess of the TS allowable ± 1% tolerance.

More NRC troubles at Fort Calhoun

Jan 21:
 The Nuclear Regulatory Commission sent Omaha Public Power District a notice in 1985 to replace Teflon as insulation in the building housing Fort Calhoun's reactor. The utility subsequently replaced it on wires that it considered at critical risk but left some in places it did not consider a safety concern.

 Commission spokeswoman Lara Uselding said her agency's oversight process relies on nuclear plant operators identifying and fixing problems while commission inspectors scrutinize that work. This system, she said, has not been successful at the Omaha plant.

"Historically at Fort Calhoun, that has not gone well and that is why they are currently under increased oversight," Uselding said.

 
I made a OIG complaint...

So I sent this to the head of Region IV OPA. I am making a official complaint against misbehavior and unprofessionalism with one of his employee. Does he have the right to retroactively block the e-mail with such a complaint, making believe they never got the complaint? Does the agency have the right to define me as a pest, thus retroactively rejecting my complaint without considering it or having a record of it.

"From: Michael Mulligan
To: "OPA4.Resource@nrc.gov"
Sent: Thursday, October 25, 2012 1:31 PM

Subject: Mr Drinks-NRC employee wrongdoing

Mr Drinks,
I 'd like to report to you I think Region IV treated me unprofessionally and disrespectfully over safety issues at the Fort Calhoun plant. In the scheme of things, this is a poor way to treat a member of the public.
I would like you to think about how the NRC treats the Palisades nuclear power plant. The poor plant NRC rating means region III has to go way above how the NRC communicates normally about a good nuclear power plant. So the NRC is disclosing any new leaks even if not required to from regulations and experimenting with novel communication approaches like webinars.
How Lara and region IV treated me is not in the spirit of region III. So there should be even better communication and more open communication from the NRC on the Fort Calhoun plant because they are a worse grade than Palisades.
I will submit, my interest in Fort Calhoun is driven by employees communicating with me over secret NRC tolerated violations at this plant.
I request you submit this to the Region IV allegations...
Mike Mulligan
Hinsdale, NH"

Say, can the agency secretly retroactively reject a complaint, meaning they read the complaint, but they were able to make believed rejecting the e-mail with prompting yahoo mail to give me a  "we were unable to deliver your message to the following address".

Is this an object lie from the NRC: "Message expired for domain nrc.gov. Remote host said: 452 Too many recipients received this hour [RCPT_TO]"

So, as example, I could make a complaint to Mr Drinks that one of his employees is accepting payola in return for secretly ignoring serious federal breaking of laws for big bucks. Then he has a officially approved way of making believe he didn't receive the e-mail. Or define me a pest so they could reject my payola e-mail without official record.

See, they don't want me to post their e-mail officially defining my region IV safety concerns as rejected by the NRC as a so called pest. This keeps my NRC concern out of their document historical record...uavailable for higher senior NRC executive, public and legal scrutiny.

I know for a fact the agency e-mail system wasn't overloaded...

 From: "MAILER-DAEMON@yahoo.com"
To: steamshovel2002@yahoo.com
Sent: Friday, October 26, 2012 4:44 PMSubject: Failure Notice
Sorry, we were unable to deliver your message to the following address.
<opa4.resource@nrc.gov>:
Message expired for domain nrc.gov. Remote host said: 452 Too many recipients received this hour [RCPT_TO]
--- Below this line is a copy of the message.
Received: from [98.139.91.68] by nm21.bullet.mail.sp2.yahoo.com with NNFMP; 25 Oct 2012 17:31:01 -0000
Received: from [98.139.91.57] by tm8.bullet.mail.sp2.yahoo.com with NNFMP; 25 Oct 2012 17:31:01 -0000
Received: from [127.0.0.1] by omp1057.mail.sp2.yahoo.com with NNFMP; 25 Oct 2012 17:31:01 -0000
X-Yahoo-Newman-Property: ymail-3X-n
Message-ID: <1351186260.6348.YahooMailNeo@web163903.mail.gq1.yahoo.com>
Date: Thu, 25 Oct 2012 10:31:00 -0700 (PDT)
From: Michael Mulligan <steamshovel2002@yahoo.com>
Reply-To: Michael Mulligan <steamshovel2002@yahoo.com>
Subject: Mr Drinks-NRC employee wrong doing
To: "OPA4.Resource@nrc.gov" <OPA4.Resource@nrc.gov>
MIME-Version: 1.0
Content-Type: multipart/alternative; boundary="1797399434-584891482-1351186260=:6348"
--1797399434-584891482-1351186260=:6348
Content-Type: text/plain; charset=utf-8
Content-Transfer-Encoding: quoted-printable
=C2=A0=0AMr Drinks,=0A=C2=A0=0AI 'd like to report to you I think Region IV=
treated me unprofessionally=C2=A0and disrespectfully over safety=C2=A0issu=
es=C2=A0at=C2=A0the Fort Calhoun plant. In the scheme of things, this is a =
poor way to treat a=C2=A0member of the=C2=A0public.=0A=C2=A0=0AI would like=
you to think about how the NRC treats the=C2=A0Palisades=C2=A0nuclear powe=
r plant. The poor plant NRC rating mean

Here is another one. So we got another: "452 Too many recipients received this hour [RCPT_TO]" and "Sorry, we were unable to deliver your message" This was the terribly insulting e-mai

From: Michael Mulligan
To: "Crutchley, Julie"
Cc: "James, Lois" ; "Schmitt, Ronald" ; "Bernal-Taylor, Sara"
Sent: Thursday, September 13, 2012 9:14 AM
Subject: Re: Email Dated March 30, 2012 re Industry Root Cause Analyses
Mrs Crutchley,
I got the big picture perfect and you know it....the reason why there is more agency findings and troubles within the industry recently.
The rules of the NRC and "Allegation" aren't fair, "Just" or ethical....this attitude isn't serving the needs of our great nation.
It is legal and according to Congress...it give you, Allegations and the agency the permission to lie to me and the public! More worrisome than that, it gives you the permission to lie to yourself.
You are bigger than that!
Mike Mulligan
Hinsdale, NH

This is the rejected message...

From: "MAILER-DAEMON@yahoo.com"
To: steamshovel2002@yahoo.com
Sent: Friday, September 14, 2012 1:45 PM
Subject: Failure Notice
Sorry, we were unable to deliver your message to the following address.
:
Message expired for domain nrc.gov. Remote host said: 452 Too many recipients received this hour [RCPT_TO]

--- Below this line is a copy of the message.
Received: from [98.139.91.64] by nm30.bullet.mail.sp2.yahoo.com with NNFMP; 13 Sep 2012 13:14:58 -0000
Re
Content-Type: multipart/alternative; boundary="1584674120-368148426-1347542097=:15500"
--1584674120-368148426-1347542097=:15500
Content-Type: text/plain; charset=iso-8859-1
Content-Transfer-Encoding: quoted-printable
Mrs Crutchley,=0A=A0=0AI got the big picture perfect and you know it....the=
reason why there is more agency findings and troubles within the industry =
recently.=0A=A0=0AThe rules of the NRC and "Alligation"=A0aren't=A0fair, "J=
ust" or ethical....this attitude isn't serving the needs of our great natio=
n. =0A=A0=0AIt is legal and according to Congress...it give you, Alligation=
s=A0and the agency the permission to lie to me and the public! More worriso=
me than that, it gives you the permission to lie to yourself.=A0=0A=A0=0AYo=
From: "Crutchley, Julie"
To: Michael Mulligan
Cc: "James, Lois" ; "Schmitt, Ronald" ; "Bernal-Taylor, Sara"
Sent: Thursday, September 13, 2012 8:34 AM
Subject: Email Dated March 30, 2012 re Industry Root Cause Analyses
Dear Mr. Mulligan,
The U.S. Nuclear Regulatory Commission has reviewed your email dated March 30, 2012 regarding industry root cause analyses. A copy of our response is attached.
Thank you for bringing these matters to our attention. If you have any further questions or comments, please contact Ms. Lois James (Lois.James@nrc.gov) or Mr. Ron Schmitt (Ronald.Schmitt@nrc.gov), or call either, toll free, at 1-800-368-5642.
Regards,
Julie Crutchley
EMAIL DATED MARCH 30, 2012, REGARDING INDUSTRY ROOT
CAUSE ANALYSES

This is the attachment..

Dear Mr. Mulligan:
This letter is in response to the concern you brought to the attention of the U.S. Nuclear
Regulatory Commission (NRC) via an email dated March 30, 2012, and a subsequent telephone call with Mr. Ronald Schmitt and staff on April 10, 2012 regarding the quality of industry root cause analyses. Specifically, you were concerned that utilities were not performing systematic analyses for problems identified at their plants.
For an issue to be processed as an NRC allegation, the NRC first needs to determine that it meets the definition of an allegation, i.e. “an inadequacy or impropriety associated with NRCregulated activity, the validity of which has not been established.” The NRC staff reviewed your concern and, based upon our evaluation of the information that you provided, determined that your concern did not meet the NRC’s definition of an allegation. Specifically, no new or site specific information was provided which would have allowed further NRC staff review and evaluation. During the telephone call on April 10, 2012, you indicated that improvements to the allegation process could be made. The NRC welcomes public input on all of our process and encourages you to provide specific, constructive recommendations.
Thank you for informing us of your concern. Allegations are an important source of information in support of the NRC's safety mission. We take our safety responsibilities to the public very seriously, and will continue to do so within the bounds of our lawful authority. Unless we receive new or specific information that suggests that our conclusions should be altered, we plan no further action on this matter.
Should you have any additional questions, or if we can be of further assistance to you, please contact me or Ronald Schmitt toll free at (800) 368-5642.
Sincerely,

This what it all revolves around...

From: Michael Mulligan <steamshovel2002@yahoo.com>To: "allegation@nrc.gov"
Sent: Friday, March 30, 2012 8:47 AMSubject: State of RCA in nuclear industry?

Sent to NRC Region I Allegations
To who it may concern:
I can't believe I am doing this after having such a painful outcome talking to NRC Region 1 Allegation officials just a few days ago. I told myself I would never talk to Allegations again. If you want to talk to me I suggest it be outside Region I Allegations and preferably somebody from headquarters. I know their are lots more experienced people in the NRC than what I was recently exposed too.
I consider Region 1 Allegations compromised much like the March 2007 Peach Bottom sleeping guard incident where Allegations needed 500% absolute perfect inside evidence that was never obtainable in our existence. The NRC was too lazy to go down to Peach Bottom to investigate it on their own and they took the false assurances of Peach Bottom that there was no sleeping guards until the inside video came out that shook up the nation.
I consider the below a "cry for help" to me from multiple plant high nuclear employees and nuclear safety officials. And I certainly assert my confidentiality rights with this because this is so explosive to many careers. Nuclear Industry safety consultants might become blacklist from the nuclear industry. It exemplifies a pervasive of "I don't care" nuclear safety attitude throughout the nuclear industry. And these utilities are disrespectful to nuclear safety oversight in general.
I bet we are painting the most accurate leading indicator the NRC has seen in decades and we know the industry is in deep troubles as seen with all of your issues in recent years. These guys got a attitude problem and so doesn't the NRC!
I wish you would send a copy of this to the OIG?
We are discussing this with Senator Bernie Sanders office and others..

..."To all,
Is no-one from Nuclear Power able to help me with this?
How does Nuclear Power know when to investigate an incident?
Are thresholds, or trigger levels defined?
Or is it merely up to a supervisor to determine what is investigated?
Thanks,
Mike Mulligan said:
It is totally unregulated when and it is totally up to a plant to define what a RCA is.
That is why nobody wants to respond...
To all,
I am getting some private responses to this question and, to be honest, I am a bit shocked.
I had thought that nuclear power was at the leading edge of much of what we talk about here on this forum (and I still think that), but the gist of what I’m reading is bothersome.
I thought there was a borderline EAGERNESS to learn from SMALL THINGS within nuclear power.
But the impression I’m getting from some of the private responses is that there’s a borderline eagerness to avoid having to investigate anything.
“Let’s wait to see if we’re forced to investigate.”
Am I getting the wrong impression?
　
I’m not sure I understand your question.
Are you asking how I came to this conclusion?
If so, it’s an impression I got from reading the emails people sent.
I asked “how does nuclear power decide whether or not to do an RCA” and the “red tape” around it seems horrendous.

Some of what I was sent seems to require a PhD to decipher.
Others hint of an “act of congress” to trigger an investigation.
So it’s just as impression I get that there’s an attitude of “let’s wait to see if we’re forced to investigate this.”
Am I wrong?

So I received these two this late afternoon Oct 27. I have no idea what is going on.

***From: "MAILER-DAEMON@yahoo.com"
To: steamshovel2002@yahoo.com
Sent: Saturday, October 27, 2012 5:21 PM
Subject: Failure Notice
Sorry, we were unable to deliver your message to the following address.
:
Message expired for domain nrc.gov. Remote host said: 452 Too many recipients received this hour [RCPT_TO]
--- Below this line is a copy of the message.
Received: from [98.139.91.66] by nm12.bullet.mail.sp2.yahoo.com with NNFMP; 26 Oct 2012 16:28:47 -0000
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X-Yahoo-Newman-Property: ymail-3Sorry, we were unable to deliver your message to the following address.

***From: "MAILER-DAEMON@yahoo.com"
To: steamshovel2002@yahoo.com
Sent: Saturday, October 27, 2012 3:44 PM
Subject: Failure Notice
Sorry, we were unable to deliver your message to the following address
:
Message expired for domain nrc.gov. Remote host said: 452 Too many recipients received this hour [RCPT_TO]
Received: from [98.139.91.65] by nm13.bullet.mail.sp2.yahoo.com with NNFMP; 26 Oct 2012 18:06:43 -0000
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