Wednesday, January 11, 2012

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



Thursday, January 05, 2012

Palisades: The higest NRC's priority is not reactor safety!

New 1/06/2012

Root Cause Evaluation Report

Plant Trip During Panel ED-11-2 Maintenance
CR-PLP-2011-4822: 09-25-11
REPORT DATE: 10-17-11
Rev 2 

 
This is how repetitively ugly it gets at a operating nuclear plant. It is so blatantly ugly at the highest levels, why didn't the NRC pick up this operational ugliness and crack heads at Palisades until they reformed. The whole bunch of them are "don't rock the boat" or "controversy" adverse. And this intimidation comes from the highest levels of the NRC and the nuclear industry, you be intrusive and controversial, we will guillotine your head off.

You can make the same case about the lack of intrusiveness with senior NRC management...they don't want to interfere with plant capacity factor or congressional campaign contribution. We'd use to like to do work overnight and on weekends, didn't want the big wig executives overseeing operational or maintenance issues. And the big wigs liked it that way because it gives them plausible deniability if things headed south. We could do all our cheating behind the sheets and everyone knew we were cheating in our darkened corners.

All the NRC executives think doing good is throwing powerless reports, non cited violations and paperwork at a plant. Doing good means making a plant do good behavior in the ends of our nation and collective good! To the NRC, doing good means fulfilling the needs of the neutered NRC's bureaucracy and rules...not nuclear safety being the overriding priority and setting conservative standards for them all. You see, the NRC thinks its their job to fulfill their bureaucracy, churn powerless rules and paperwork, but never interfere with plant operation and capacity no matter how ugly it gets. Is their internal processes fulfilled, but very few of them check their conscience to see if the NRC processes are making a utlity behave for the good of the nuulear industry and our nation? 
They talk about the generation x'ers being so spoiled, somebody saying boo to them will cause them to quit?

The recent history of Palisades is they keep throwing reports at them and nothing changes.

The whole history of the NRC is they are adverse to really engage a plant...until a plant gets in enough trouble where it threatening the whole regulatory régime. Being serious with Palisades is now a NRC operation to contain regulatory credibility. 

HEADACHES AT PALISADES: BROKEN SEALS & FAILED HEALS

NRC's response to Dave:

"Leakage from the CRDs has historically started small and slowly risen over time, typically over several months. The licensee monitors CRD seal leak-off temperatures each shift and this parameter has proven to be a reliable, real time indicator of seal degradation. Based on these and other indications discussed below, operators have always had advance indications of seal leakage approaching an amount that, by procedure, requires action."

Reminds me of the service water coupling...

My concern, lessens learned in the Davis Besse head control rod drive leak, a leak like this could obscure a more important leak indicating a more serious safety issue. Could a non safety leak obsure a safety significant leak? DB had notorious pressurizer or letdown relief leaks over decades...these reliefs valve leaked over and over again. Even through these relief valves weren't leaking, DB improperly blamed the dangerous head lead leak on these relief valve leakage. A phantom non safety relief leakage based on poor maintenance could obscure a very serious ongoing reactor system pressure barrier leakage.

As example, the reactor head or other important piping might begin to be cracked and leaking...Palisades would assume it is just a control rod drive seal leak and think they got months to shutdown.


Detecting containment air radiation is a sensitive means to detect reactor leakage. Again a control rod seal leak will obscure the measurement of containment air radiation.
The trick is, how positive is the indications of the control rod seal leak is for the plant operators. In the primary containment they have very limited means to actually see what is leaking...


...And remember, this is not a leak of pure water. There are high concentrations of boron in the coolant and there are worries about the results of plating out boron on the containment coolers and other components. It also makes the interior of the containment more radioactive and difficult to perform maintenance on.

How about in Aug 10, 2004 they shut downed for a control rod leak and reactor coolant pump leak and maintenance issue. How could they tell the what leakage came from where. 

New 2:50 p.m. CST 1/5/2012



Palisades plant going offline for maintenance work

COVERT TOWNSHIP, Mich.— The Palisades nuclear power plant in southwestern Michigan is being shut down temporarily for maintenance

...It is unfathomable how many times Palisades has been shutdown to fix their control rod drive seals. I believe these things can leak for a long period of time before they are required to shutdown. One wonders last MFP recirc valve trip if these seals were known to be leaking and they failed to fix it?

What can be said for sure, tripping and restarting this plant to this magnitude damages these big machine and weakens the fuel cladding!

New 01/05/2012 11:25am
Things heating up?  
NRC issues violation notice to Palisades nuclear power plant

The NRC only has the power to write reports after the accident and paper whip a plant through the useless ROP!

These are my examples the NRC is a toothless regulator...the regulator can only write reports after the accident happens. They have very limited capabilities to change bad behavior of a bad nuclear power plant because of campaign contributions and heavy industry influence. The regulator don't have the power to change bad utility behavior.  


It is interesting, I talked a little about ceremonial power and real power yesterday with NRC Region III allegations people over Palisades. Just because of your ceremonial power, who you are and the position you hold, sometimes this gives you the power to shape the outcome of events without having direct power to influence a event. We were talking about the DC short and the MFP recirc valve misoperation leading to a scram. I was telling these officials you might not have direct influence through regs, but you always have the ability to potentially change a heart over a situation through the ceremonial power you carry. The NRC branch manager popped up, "well I tried that with calling a high Palisades nuclear plant official asking him to say shutdown until they understood what caused the MFP recirc valve trip". I was very disappointed with this off the record back door channel to Entergy with the NRC...

By the way, this is a little humor on the Aux Feed Pump spurious trip, maybe the MFP recirc valve operation trip is another spurious trip. To this day, the NRC and Entergy still does not know what caused the MFP recirc valve plant trip. I consider Entergy's AFP spurious trip theory that the NRC won't accept as attempt by entergy to exhaust the resources of the NRC. If we keep the NRC busy on defending themselves or running down useless branches of a event, they won't have the time to find all the other crap we are not disclosing doing because of very limited NRC resources.

1) Considering how bad Palisades is, the NRC should have had the power to make them stay shutdown until this organization fully understands the MFP recirc valve trip and correct all the factors that caused the plant trip.

2) The NRC with the DC short on Sept 23 through the shorted and erratic control room indications prior to the scram should have declared a emergency stop work order and immediately required a reactor scram.

We got another runaway oil well in the gulf of Mexico, everyone knows it is drastically unsafe, but nobody's got the power to make them stop drilling to prevent a gulf catastrophe...

PALISADES NUCLEAR PLANT - NRC SPECIAL INSPECTION TEAM (SIT) REPORT 05000255/2011014 PRELIMINARY YELLOW FINDING

"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

Wednesday, December 28, 2011

Emergence of systemic meltdown of Entergy?


01/03/2012

Based on recent events and post red inspection findings at Browns Ferry with NRC tolerance of a site not being according to their rules, policies or procedures...I could make a case the NRC catch regulation violations now  to a tune of a third to one half of all known  or potential violations. In other words, all these plants are littered with tons of not corrected known NRC and engineering violations.

With acceptable not disclosed violation, this is a serious poison to any safety culture or nuclear plant. The implication are if a good employee admits the violation he would be intimidation by his management and the NRC because the NRC finds the non disclosed violations acceptable.
12/27/2011@ 6pm
 "So palisades had had 5 shutdowns this year, the last one a secret start up without knowing what caused the trips, Pilgrim on it third trip with one being a very serious startup trip, Fitzs is reducing power beginning Dec 23 for a condenser leak, and River Bend is just starting up from a prolong shutdown."

"You cheap out on maintenance and personal, then you have more trips, NRC
and public scrutiny..."

 "Yea, because it was unsafe...

Imagine a new plant designed to not have failing parts or them failing being inconsequential.

Usually they know about the leak for many months..."

12/28/2011
"Turbine Problem Trips Reactor at Louisiana's River Bend Nuclear Plant...

The reactor at the River Bend nuclear plant in Louisiana shut down automatically after an issue in the turbine caused safety systems to trip."

"I thought these guys were smart, why didn't they have a fifth or sixth relief valve...you only need 4 reliefs...so you just shut the isolation valve and continue on to the next outage."

Sunday, December 18, 2011

Saddam Hussein's nuclear industry billionaire palaces

...The government is also considering setting the maximum lifespan for nuclear power plants at around 40 years, they said. The Fukushima No. 1 plant has been running since the 1970s.

Hmm, the nuclear industry’s daddy is the same daddy as the coal, natural gas and the lying green energy sources....all the energy sources that supply our electricity. You got a penny pinching selfish father who for pennies of benefits on the big picture, that is destructively playing his children off against each other.

What makes the nuclear industry so vulnerable is their penchant for secrecy...the right wing has to have secrets in order to be. It is the secrets that gives him the advantage, not hard work and creativity...creating a better world for us all.  

My general complaint with the nuclear industry...nuclear safety... is a they are driven by a distructive 1%er right wing ideology. I think the nuclear technology is a precious gift to us all.

As far as trading lives and jobs with Japanese, there is still 130,000 people who has had their homes stolen from them by the nuclear right wing genie. They are still displaced by the horrors of a of a nuclear accident. I suspect not many of them even have a job and the genie has stolen many jobs not related to the nuclear industry...

I would frame the real and powerful anti nukes as the utility and financial daddy who structures the whole nuclear industry for his singular selfish interest? The real anti nukes are the extreme pronukes who would align the nuclear industry and safety for solely individual gains of the 1%ers and themselves.

I would frame it as the corporate vampires, did you ever see the ostentatious middle east Saddam Hussein's palaces these utility CEO’s have build from themselves...they always just about suck the life blood out of the nuclear technology in order to live like billionair middle east thug kings. The home palaces and the corporate palaces. If they would have plowed back more profits to update their nuclear plant design over the decades instead of the feeding the ostentatious and gilded lives of the corporate utility executives and their really expensive cheater bar Washington and state k street political empires...we’d all be a lot better off. Remember the nuclear industry for decades has been the golden calf for these executive kings. And remember the whole electric industry infrastructure has been starve for funds through the utility 1%ers and the captains’ of the large users of electricity 1%ers.
 
  

Saturday, December 17, 2011

Palisades MFP recirc valve shutdown and restart!

Dec 17, 2011

This is not the story the NRC told me yesterday.


One day outage is third in past three months for nuclear plant

Published: Saturday, December 17, 2011 1:06 PM EST

Following repairs to the valve that caused the pumps' automatic shutdown, the plant returned to production at 11:45 p.m. Thursday, plant spokesman Mark Savage said.
From: Michael Mulligan
To: "allegation@nrc.gov"
Sent: Saturday, December 17, 2011 10:41 AM
Subject: Palisades MFP recirc valve shutdown and restart!

To Chairman Jaczko (and allegation)

By the way, the region III NRC public relation people were saying coming from the on site inspector...Palisades was allowed to startup without knowing the cause of the MFP recirc valve misoperation. As of late yesterday afternoon, they were researching the maintenance history of the valve after the startup.

Basically, they were allowed to take the broken valve off line, then immediately start up the reactor. Then trouble shoot and fix it at power. She said it was a non safety system, the NRC doesn't have any authority over this kind of plant operation.

I asked the NRC, the last DC short the NRC doesn't have the guts to declare a stop work and required a immediate shutdown to repair the DC ultra safety system before the flickering lights in the control room and the plant trip while not following procedures. So now you are saying to me the NRC didn't have the horsepower to keep the Palisades plant shutdown until everyone fully understood the broken MFP recirc valve and the organizational problems that drove it, in one of the worst operated nuclear plants in the USA. Are we going to discover in the American Fukushima the NRC had a radical reactionary stance...afraid to get ahead of the developing problem and the agency failing to assert their authority to protect our safety and security?

She said this moved them from green to white on the ROP with unnecessary shutdowns...5 shutdowns in the last year...

I hope i am not seeing the NRC and the plants being timid over the internecine warfare going on in the commissioners office...especially plant information. We are not sure what the hell is going on in NRC commissioners office, so just don't disclose anything is the safest avenue.

It seems the more trouble Entergy gets into...the more reckless they become in asserting to their investors and to the nation in general that our nuclear plant troubles will not interfere with our capacity factor!

Mike Mulligan

Hinsdale, NH

16033368320

Saturday, December 03, 2011

Request Emergency Palisades shutdown

NEW 12/15:

Spent a lot of time talking to the region III pr person. She says Entergy tagged it out or took the valve off line, then they started up without knowing what caused it or looking into the historic record.

Palisades nuclear plant down again, this time awaiting repairs after feed pump issues Wednesday

Thursday, December 15, 2011, 12:01 PM Updated: Thursday, December 15, 2011, 12:04 PM

The plant has been plagued by problems in recent months.

"The reactor was manually tripped at 1510 EST on 12/14/11 due to loss of both main feedpumps. Both feedpumps tripped on low suction pressure due to an apparent unplanned opening of the 'A' main feedpump recirculation valve. The cause of the main feedpump recirculation valve opening has not been determined. All full length control rods fully inserted. Auxiliary feed pump P-8A automatically started at 1511 EST on steam generator level as designed (10CFR50.72(b)(3)(iv)(A)). The turbine bypass valve is in service maintaining reactor coolant system temperature [by directing steam flow to the main condenser]. The plant is stable in mode 3 [and the reactor trip was considered uncomplicated]."


"All these past problems are effectively working their way through the beast now, all within their discovery and correcting phase. These things are never black and white at these nuclear plants. We got the continued problems like they discovered last inspection and the ones that are going to occur next inspection. This is a big problem with the NRC. They don't really actually know where we exactly stand. We got all these past but not fully corrected problems, the falsification and inaccuracies. We are not sure in what state of discovery and correction phase they are in; the ones we just discovered and the one identified but repeated ones over and over again. How then the multitudes of serious ones we have not yet discovered, but they are simmering active below the surface unseen. We really don't understand where these problems are in the temporal dimension on the big picture (chronologic, sequential, threat, in stages of completion, there is such a long latency period between emergence of the error and its fix), we know these errors and defects are all spinning around in the organization and in the ether. We have no framework to understand what is the totality of risk or threat to plant reliability right now. We have no quick, we have no visually representation of what happened, what is broken or degraded, what is going on right now, what is going on in the future...like a Thinkmap Visual Thesaurus."

"We are basically plowing along in a car in Midtown Manhattan without ever having been there before and driving by feel."

Sunday, November 06, 2011

Documents show heavy Entergy lobbying on Vt. nuke

By Dave Gram
Associated Press / November 6, 2011

"A central issue in the Vermont Yankee case is whether the state is pre-empted by federal law from requiring that the Vernon reactor shut down when its initial 40-year license expires next March. The NRC announced in March of this year that it would grant Vermont Yankee a 20-year license extension"

You can extract lot of information out of this. What happens to federal preemption if the NRC was found to be incompetent with radiological oversight at VY and they have a instinct for pubic falsification. At the end of the day, what enables this culture of lying and falsification is their ability totally to define agency secrets...no oversight of the agency.
 By: PETER BACQUÉ Richmond Times-Dispatch
Published: November 06, 2011
According to the memo, written by U.S. Department of Justice attorney Bradford F. Whitman, his investigation determined that Vepco had a "consistent policy" of not filing "any formal document" that would have informed the Atomic Energy Commission's licensing board and the public about the fault.
At the same time, "virtually the entire Office of Regulation of the (Nuclear Regulator Commission was) …well aware of the fault and determined not to take any immediate action" to stop the plant's construction or reopen the licensing hearings, Whitman wrote in the 1977 memo, which the Richmond Times-Dispatch recently obtained.
The Nuclear Regulatory Commission replaced the Atomic Energy Commission in 1975.
Though making false statements to a federal agency is a felony, Whitman recommended against prosecuting Vepco for its alleged failure to disclose the fault because the company's federal regulators participated in the effort to keep the fault quiet.
"It was a really difficult thing for us to do anything as prosecutors because our client agency … was involved," Whitman said Friday. The government "wasn't deceived, it was part of it.
 This proves that a utility and the NRC has a prediliction to lie and do blanten cover-ups...because the agency knows they will never be held accountible. And here we sit in a huge over-up at VY?

Saturday, November 05, 2011

Why the NRC Cover-up, because its "game changing".

Got to give credit the NRC put it up on their document system.
This is to remind people my memo is on the VY docket...in the NRC's website.

'Addendum to 2.206 petition from Michael Mulligan'


Oct 20,2011:"This has been one of largest cover-up operation of the NRC in many years and there is certainly high level NRC officials being involved. The PRB's response to me that I had insufficient evidence was a malicious fabrication....the PRB's response to me was maliciously inaccurate and a falsification considering CR-VTY-2011-03628 and the NRC questioning that went on at the plant."


Added: I think this is a NRC insanity thing with the cover-up...a dysfuctional organizational behavior under extreme stress.

Ok Mike, so why the NRC cover-up over the Vapor extractor plume. As Exelon's CEO said, fracting natural gas makes the new nuclear plants uncompetitive. Most of the drastic increase in NRC personnel and budget increases came about from the potential with the new nuclear plants. What are they going to do with these excess employees' and their dreams. I think the dream of all these new employees has been killed and most of the rest of them are disillusioned. I don't know, they are under the gun as never before, does that make them more cohesive and more easily commit a cover-up. You know, they are going to have to work in the third world technology for the rest of their lives. Then you had Fukushima and the VY licensing issues. I just think the employees have become overly insecure about the conditions of the industry...thus the sensitivities about unmonitored radioactivity steam plumes above VY.

I just think the Washington NRC folks sees their jobs disappearing and they are all threatened...thus the cover-up wishing they would do whatever it takes to preserve nuclear industry jobs and nuclear industry credibility.

This is the biggest existence to threat to the nuclear industry ever. It is going to profoundly change the NRC into just managing the aging fleet into extinguishment. It going to mean a lot less employees. And what young engineer wants to spend all of their lives putting to bed a dinosaurs dangerous technology...

Shale Gas Revolution
By David Brooks
Published: November 3, 2011

Exelon's Rowe an unlikely booster for shale gas
By Andrew Maykuth
Posted: Sun, Oct. 30, 2011, 3:00 AM

"John Rowe, the chief executive of the utility Exelon, which derives almost all its power from nuclear plants, says that shale gas is one of the most important energy revolutions of his lifetime. It’s a cliché word, Yergin told me, but the fracking innovation is game-changing. It transforms the energy marketplace."

"Game changing"

The U.S. now seems to possess a 100-year supply of natural gas, which is the cleanest of the fossil fuels.

Today, natural gas prices are less than half of what they were three years ago, lowering electricity prices. Meanwhile, America is less reliant on foreign suppliers.

"John Rowe, the chief executive of the utility Exelon, which derives almost all its power from nuclear plants, says that shale gas is one of the most important energy revolutions of his lifetime."

"The shale gas revolution challenges the coal industry, renders new nuclear plants uneconomic and changes the economics for the renewable energy companies, which are now much further from viability".

"Rowe, whose Chicago company owns Peco Energy Co., said in an interview Friday that before shale gas came along, Exelon made so much money generating power in high-priced electricity markets that one of his company's main concerns was "how to keep people from taking [the profits] away from us."

"You watch next year our earnings will be down compared to this year, and the principal reason for that will be low natural gas prices," said Rowe, who was visiting Philadelphia to speak to Wharton Energy Conference 2011 at the Union League."

"I cannot build a new nuclear plant to compete with gas." Rowe, 65, told the Wharton audience. "I cannot build a new nuclear plant to compete with what China can build.... But I can build gas-fired capacity in ways that allow Pennsylvania to compete with China."








 

Wednesday, November 02, 2011

Timeline

Timeline

Aug 26, 2011
Submitted inaccurate radiological environmental 2.206 for VY

Sept 8, 2011
Requested NRC's Tom Setzer to help me with turbine building plume.

Sept 12, 2011
VY submitted my concerns about plume through CR-VTY-2011-03628.

Sept 14, 2011
Testimony to NRC PRB.

Oct 4, 2011
PRB made recommendations .

Oct 11, 2011
NRC notified me on recommendation that I "provided insufficient facts".

Oct 12, 2011
Called Vermont State nuclear engineer and requested he investigate facts.

Oct 14, 2011
State engineer called back: it is a unanalyzed plume, no paperwork ever, coming from turbine steam, got tritium in it, VY hired Areva to sample and investigate, VY entered CR-VTY-2011-03628 in their document system.

Transcipts: VY radioactive plume and NRC coverup


Mr. Mulligan, I will turn it over to you
5 to provide any information you believe the Petition
6 Review Board should consider as part of this petition.

7 PETITIONER MULLIGAN: Thank you, Mr.
8 Hiland.
9 Words are, the definition of words is,
10 pretty important in this thing. You spoke of the
11 Petition Review Board discusses this with me. You
12 have done it repeatedly over I don't know how many
13 petitions, but not once has anybody ever discussed
14 anything with me. You usually send a
15 couple-of-sentence explanation on what is going on and
16 that type of thing. It's never discussed. It's
17 always in a written form. So just if words mean
18 anything, I just wanted to bring that up.
19 I was curious, you know, why my full 2.206
20 petition is not on the Vermont Yankee docket. It
21 might be there. I looked a couple of times. I
22 couldn't find it. There are a lot of issues with the
23 search features on the NRC site, but I am surprised
24 that 2.206 isn't on the docket itself, the whole
25 thing.
1 I spoke a lot in the beginning about
2 Palisades. And I last testified on October 26th and
3 on September 19th at Palisades. They had a reactor
4 trip. And they found a broken valve, and there was
5 leaking.
6 Then on September 26th of the same year,
7 they had a broken breaker. And so I am just making
8 the case with that petition that Palisades and Vermont
9 Yankee are related in that it is operated by Entergy.
10 I think the major fault with Entergy is
11 they haven' t developed a strong centralized management
12 system. They usually defer their management to the
13 local plants and stuff.
14 There is a lot of under-funding that goes
15 on and not adequate skills. And that's where a heart
16 of a lot of these problems lie. I think that in a big
17 organization, there has to be a strong centralized
18 power that creates order in all of the branches, the
19 rest of the organization.
20 In my last testimony, I said, "Well, you
21 know, I know the NRC is in a process. I will know
22 when the NRC is in a process of repairing itself when
23 they redo the 2.206 process." I basically think we're
24 there with this.
25 I think essentially the NRC maliciously
1 goes through this NRC process. And the outcome is
2 known to be inaccurate and falsified and corrupted.
3 You might go through the process. You
4 might obey all the rules and stuff, but the outcome
5 leads to a false outcome and stuff. And everybody
6 knows you guys sign your names to these things. And
7 if it's inaccurate and if it's intentionally
8 inaccurate, there should be legal remedies.
9 On April 26th, Mr. Hiland was talking
10 about on the roof and trying to figure out where the
11 plume was going, where the plume was coming out of the
12 turbine building. I mean, you know, it's a picture
13 taken a couple of miles away.
14 I was kind of perplexed at that type of
15 thing, asking those kinds of questions. If I was a
16 confident agency and they were working for me, the NRC
17 would have had inspectors up on that turbine roof.
18 And they would have been feet away from it. And we
19 wouldn't be playing word games with how many
20 stanchions away is the plume. We would have known.
21 The inspectors would have been up there. And it would
22 have wrote an accurate report about it. And we
23 wouldn't be playing these kind of games. We're trying
24 to figure out what a photograph is saying.
25 It should be mentioned two days prior to
1 this, Entergy wrote up a condition report about the
2 plume, about my plume. They essentially admit that
3 it's an unanalyzed discharge. There's no
4 documentation at all with this through the history of
5 the plant. And they hired AREVA to do an
6 investigation and evidently take samples of the stuff
7 coming out of the pipe. It's too bad that we didn't
8 get that before the shutdown.
9 The theme here is there might be generic
10 issues with other plants as far as should they have
11 similar AREVA investigations as Vermont Yankee? You
12 know, a possibility if Entergy and NRC wanted to get
13 VY into an outage and on the other side of the outage
14 without making any modifications because they don't
15 have to take measurements if there are issues of
16 getting VY past the court case? And everybody could
17 have been stalling because of that.
18 And, you know, there are issues of
19 incompetent relicense of Vermont Yankee. How come
20 this wasn't caught during the relicensing problem?
21 Did not meet the criteria for review
22 because the petitioner failed to provide sufficient
23 facts that would warrant further inquiry. You're
24 right. You know, like I just talked in the beginning
25 of this thing, you know, I knew that the system wasn't
1 providing me with the facts that were ongoing at the
2 plant with the AREVA contract and condition report and
3 stuff.
4 So essentially two days before this, my
5 testimony, the completion of it, was this condition
6 report and stuff. And I know a lot of people were
7 wondering, asking questions about this and stuff like
8 that. And this evidence wasn't given to me prior to
9 the Petition Review Board meeting.
10 I think it's a cover-up. I suspect
11 there's a -- it's a pretty serious cover-up because
12 this stuff was withheld from me. And, you know, it
13 wasn't really withheld from me. It was withheld from
14 the public.
15 Honest guy asks an honest question. And
16 it was absolutely accurate and stuff. Everybody was
17 fiddling around behind the scenes, you know, in the
18 secret document chambers that the public can't get at.
19 And everybody could play like stupid, you know, "We
20 don't know what you're talking about, Mike. You have
21 insufficient evidence." You know, this is one of the
22 worst coverups I've seen in the NRC in a long time.
23 I would like to go over the timeline on
24 our August 26. I submitted the 2.206 and accurate
25 radiological environmental reports coming out of the
1 turbine building plume.
2 On September 8th, I made a request of Tom
3 Setzer to help me with this. Again, you know, like
4 you said, "Mike, you've got the Freedom of
5 Information. And you've got all of these ways to get
6 information, Mike."
7 You got 100,000 processes, but nobody
8 wants to talk to you. I mean, that's what the NRC
9 always come back to me with, "We've got all these
10 processes."
11 But you make an honest effort to talk to
12 somebody about a problem, like Mr. Setzer. And he
13 stiff-arms me by not answering me back. And I suspect
14 that's not an error with Tom Setzer. I suspect that
15 his bosses told him that's how they're going to
16 respond to Mike Mulligan, is to stiff-arm him.
17 So on September 8th, I made a request to
18 Tom Setzer to help me out with the developing
19 condition report and AREVA contract to figure out what
20 is going on with that plume.
21 On September 12th, like I said, Vermont
22 Yankee submitted a condition report, or
23 CR-VTY-2001-03628, rad pathway unanalyzed.
24 On September 14th, two days later, we had
25 the Petition Review Board. Just one wonders. Two
1 days beforehand, you know, all the stuff going on
2 behind the scenes as far as Mike is right and then
3 everybody coming to the conclusion that it's an
4 unanalyzed pathway.
5 There are no documents at all with this,
6 at all. It's mind-boggling to think that there are no
7 documents at all associated with the vapor extractor
8 emissions.
9 So what did I get down to? The September
10 14th Petition Review Board. It's when Vermont Yankee
11 had the evidence sitting in their hands. And, like I
12 said, you know, whether Mr. Entergy at these
13 proceedings could have talked to me about it or made
14 a few comments about it or Tom Setzer himself.
15 These people knew that I was right. They
16 essentially gave the environment of insufficient facts
17 for the Petition Review Board, which was wrong. It's
18 absolutely wrong.
19 And, like I'm saying, these people had had
20 the opportunity to be honest and truthful and admit
21 what was going on and explain it a little bit, but the
22 system -- you know, that's the way the system works,
23 forward a system to a falsified outcome.
24 And everybody is just getting sick and
25 tired of that. You know, I thought we were supposed

1 to be honest and ethical. I thought we were supposed
2 to be focused on a higher good, a societal good type
3 of thing and not, you know, necessarily following the
4 procedures and processes.
5 The processes and procedures doesn't make
6 it ethical and truthful and righteous, the outcome.
7 You know, it doesn't create the honest story of really
8 what was going on and what happened and what we are
9 going to do in the future.
10 So on October 4th, the PRB made the
11 recommendation. I didn't get the recommendation until
12 October 11th, 2011.
13 On October 12th, I called Uldis Vanage,
14 the Vermont State Nuclear Engineer, and left a
15 recording on his phone. The spelling of his name is
16 U-l-d-i-s V-a-n-a-g-e. I still have a hard time
17 pronouncing his name. So I left a recording on it.
18 You know, I told him my story and left a recording on
19 his name, nice picture I gave him, too.
20 On October 14th around, Mr. Vanage called
21 me back, explained -- I explained my story, said he's
22 heading to Vermont Yankee to ask my questions.
23 On October 18th, 2001, the State Nuclear
24 Engineer reported back his results of his talk with
25 Entergy, you know. I couldn't get this out of -- you
1 know, Entergy was quiet. I couldn't get it out of the
2 NRC in the Petition Review Board and stuff, you know.
3 What kind of -- how do you get information? How do
4 you get information from people when the Board kind
5 of, you know, through its rule says you can't give
6 information out to Mike Mulligan?
7 You know, you say it's a one-way check
8 valve we've got going here. I have to abide by strict
9 legal precedences. And you guys get to use ghetto
10 laws and stuff like that that nobody can understand.
11 You make up your own rules behind the scenes that
12 nobody can understand and ghetto drug laws or however
13 you want to term it, these laws that really don't have
14 any foundation of serving society and the greater
15 good.
16 So he reported that there is definitely a
17 plume. He got this from Vermont Yankee. It is coming
18 from the turbine seals. It is coming from the turbine
19 seals. And maybe seal steam is getting into the lube
20 oil or the suction of the lube oil. There is tritium
21 released from it.
22 It is unanalyzed and undocumented through
23 the life of the plant. And Entergy -- like I said,
24 Entergy hired AREVA to do an evaluation of what
25 happened for the license basis.
1 That reminds me. I hope you got my last
2 email of kind of memorializing this.
3 Hello?
4 MR. KIM: Yes. We received your email.
5 And it has been disseminated to the PRB members.
6 PETITIONER MULLIGAN: Okay. Thank you.
7 You know, I say that the state engineer
8 says that he only wanted to talk about tritium, but I
9 believe it has all the components of reactor vessel
10 steam stuff.
11 And, you know, basically -- and this isn't
12 a little thing. I mean, to give people a little bit
13 of background, you have got tons of engineers at
14 Vermont Yankee. They're like ants. There are lots of
15 them and stuff. I know they're busy now in that
16 thing. And they all have -- most of them have good
17 degrees. They come from good colleges. Some have
18 advanced degrees.
19 Certainly the NRC is in the same way. You
20 know, these guys were all -- they have all a lot of
21 experience. And the NRC people have, you know, even
22 broader experiences. You know, engineers at Vermont
23 Yankee are experts at Vermont Yankee.
24 But the engineers with the NRC that are
25 associated with operation of these plants, I mean,
1 they have information on many plants. And, you know,
2 they have a greater view, wider view, of the nuclear
3 world and stuff like that.
4 So, you know, there's a lot of experience
5 here on both sides of it, a tremendous amount of
6 experience. You know, how could all these people miss
7 this through all these years?
8 You know, it's just mind-boggling to think
9 that somebody couldn't see that plume up there and
10 say, you know, "How is that damn thing in documents?
11 How do we get that thing -- how do we got our asses
12 covered?" And it was missed. It's at the end of
13 life. And something like this is missed at many
14 plants. Like I said, it raises generic issues at
15 other plants.
16 Like I said, in my 2.206 last time, I
17 begged for information on what was going on here.
18 And, according to your process, you were prevented
19 from giving me the information.
20 I mean, I don't think anybody, I don't
21 think Mr. Entergy was prevented from giving me the
22 information. I don't think Mr. Setzer was either. I
23 think he could have spoke up and said something, you
24 know, "This is going on" or something like that. But
25 the process says, you know, "You've got to lie by
1 omission." Everybody's got to lie by omission.
2 Everybody's got to be untruthful by omission.
3 It's okay to be dishonest because the
4 procedure says it's okay. It's allowed. And, you
5 know, I think there's something more here, you know.
6 That's really important.
7 I'll give my blocks another thing. It's
8 the Potterville Town Hall if anybody wants to see the
9 pictures and my write-up of it. I think this
10 constitutes a pervasive attitude with the NRC and
11 Entergy with an inability to tell us the truth. You
12 know, I think it's -- I think their systems allow them
13 to not tell the truth, you know. They can play the
14 rules, and the outcome can be untruth. I just think
15 that can't happen. That shouldn't be happening. That
16 shouldn't be happening in the United States of
17 America.
18 Malicious compliance with agency process,
19 knowing the outcome is not ethical, a falsification.
20 I believe that with all of my heart.
21 You've got to wonder if there's shredding
22 of documents going on at Vermont Yankee.
23 (Pause.)
24 PETITIONER MULLIGAN: I'm just going
25 through my paperwork here for a second to make sure
1 I've got everything.
2 The Catholic Church has an interesting
3 take on -- with their economic report recently about
4 the world situation with our financial system. And it
5 talks about technology and how we can't turn
6 technology into materialism or ethic or rules or use
7 technology for excessivity for personal benefit, what
8 I'm thinking of, the whole of the planet. It says
9 that, you know.
10 The soul of the NRC isn't the rules and
11 regulations. There's got to be something above rules
12 and regulations. I mean, in intelligence, there's got
13 to be something. Rules and regulations are primitive.
14 There's got to be something higher than rules and
15 regulations.
16 And intelligence is the ability to catch
17 associations, the ability to be fixated on something.
18 You know, you might get turned off a couple of times
19 or turn the wrong corner but, you know, the
20 intelligence to keep at it until you find a problem
21 and stuff like that.
22 There's a sense, you know, of the soul of
23 the agency, who they serve and what do they think of
24 human dignity. Human dignity is not found really in
25 a group of people. You could respect a group of
1 people but each other. And you can respect the
2 group's dignity, but you might disrespect the greater
3 societal dignity by over-focusing on group behavior
4 and not -- you know, where are we heading? Where are
5 we headed?
6 Here is a quote if I can just spend a
7 couple of seconds. "However, if we think clearly
8 about the new social question, we must avoid the
9 error, itself a product of neo-liberal thinking of
10 regarding all problems that need tackling as
11 exclusively technical in nature. In such a guise, the
12 problem evades discernment and ethical evaluation that
13 are urgently required. In this context, Benedict
14 XVI," I think, "encyclical warns about the dangers of
15 technical ideology; that is, of making technology
16 absolute, which tends to prevent people from
17 recognizing anything that cannot be explained in terms
18 of matter alone. It also minimized the value of
19 choices made by the concrete individual who works in
20 the economic financial system by reducing them to mere
21 technical variables, being closed to the beyond in the
22 sense of something more than technology not only makes
23 it impossible to find an adequate solution to the
24 problems but empowers the principal victims of the
25 crisis more and more from a material standpoint."
1 You know, all you've got to do is replace
2 "financial economic" with "nuclear power" and stuff.
3 And that essentially asks us the question, is there
4 something more than technology?
5 And, you know, of course, language is
6 being used more and more as a technical instrument.
7 You know, language is engineered processes are
8 created. Outcomes are assured.
9 You know, language becomes technically
10 engineered. You know, you can abuse language in the
11 same way as you can abuse the financial system.
12 You know, I talked a lot about this, about
13 how the NRC comes up with a process that's immoral.
14 It's the same way with language. And in a lot of
15 ways, we use language. Most our institutional
16 problems and failures are related to using language as
17 a technology to come to a predetermined outcome, to
18 force people to come to a predetermined outcome, and
19 not use their greater intelligence to really figure on
20 what is going on and what is best for us.
21 And so I just want everybody to realize
22 that language is important on how we use it. And we
23 can use it for good or we can use it for bad. And
24 this technical language that everybody uses nowadays,
25 you know, it's particularly potent. It can be used
1 for unbelievable, wonderful things. And it can be
2 used for some really nasty stuff.
3 Just one more quote from this guy. "As
4 Benedict XVI exhorts us, agents on all levels, social,
5 political, economic, professional, all are urgently
6 needed to have the courage to serve and promote the
7 common good through an upright life. Only they will
8 succeed in living and seeing beyond the appearance of
9 things and perceiving the gap between existing reality
10 and tried possibilities." This is unbelievable.
1] "Pope Paul VI emphasized revolutionary
12 power of forward-looking imagination that can perceive
13 the possibilities inscribed in the present and guide
14 people towards a new future.
15 "By freeing their imaginations, humans
16 free their existence. Through an effort of community
17 imagination, it is possible to transform not only
18 institutions but also lifestyles and encourage a
19 better future for all people."
20 I think that's important: our souls and
21 the souls of our organizations and how we serve some
22 higher purpose.
23 You know, one last thing is the pope says
24 -- well, not the pope. The church says, "Unity is
25 truth." You know, it kind of says, you know, if we
1 come to unity, you are almost god-like or over
2 cosmic-like and stuff like that. Unity is truth. It
3 couldn't be more beautifully expressed.
4 Thank you very much for allowing me to
5 speak.
6 CHAIRMAN HILAND: Are you finished, Mr.
7 Mulligan?
8 PETITIONER MULLIGAN: Yes, sir, I am.
9 CHAIRMAN HILAND: Okay. At this time does
10 the staff or anyone here at headquarters have any
11 questions for Mr. Mulligan?
12 (No response.)
13 CHAIRMAN HILAND: Hearing none, does the
14 staff in Region 1 have any questions?
15 MR. DeBOER: I do not.
16 CHAIRMAN HILAND: Does the license, who I
17 believe is listening on the call, have any questions?
18 MR. DeVINCENTIS: No, Entergy has no
19 questions.
20 CHAIRMAN HILAND: Okay. Before we
21 conclude the meeting, members of the public may
22 provide comments regarding the petition and ask
23 questions about the 2.206 petition process.
24 However, as stated at the opening, the
25 purpose of this meeting is not to provide and
1 opportunity for the petitioner or the public to
2 question or examine the Petition Review Board
3 regarding the merits of the petition request.
4 (No response.)
5 CHAIRMAN HILAND: Hearing no members of
6 the public, Mr. Mulligan, thank you for taking time to
7 provide the NRC staff with clarifying information on
8 the petition you have submitted.
9 PETITIONER MULLIGAN: Thank you, sir.