NRC Acknowledgment of Palisades 2.206

Me

To Chairman@nrc.gov

Mar 11

Dear Chairperson McFarland,

If you really believed this from your recent speech…

“As we continue to strive for effective, credible regulation, and assist other regulators in upholding these values, our commitment to continuous learning is critical. I believe that when we demonstrate that our decisions reflect the best available information, and when we demonstrate openness to external interlocutors, it enhances public confidence. This is an objective I’ve embraced since my tenure at NRC began, and I continue to believe in its importance. 

 

…you’d help me gain much better transparency in my upcoming Palisades 2.206. The 2.206 processes for an outsider are a travesty and circus. It is designed for an outsider to fail most of the time because of a lack of evidence. It should be a firing or disciplinary offence if a NRC employee ever misleads a petitioner or to withheld information from inside this process. You’d make a licensee answerable to my questions or severe consequences.
 

How about all petitioners’ activities and the whole process be recorded and put on your NRC internet site?

There is a tremendous difference in power between me and the NRC/licensee...while you guys have almost unlimited god like powers to withhold information based on unseen justifications. I remain utterly powerless and have no rights of transparency within this process. But I do have the right to get my letter in the NRC documents, and of course, I get a shot for you to transcribe my words by a telephone bridge to many NRC employees. I have to admit there is substantial power in this for a petitioner.
 

If you really believed what you wrote, you would help me overhaul the NRC’s 2.206 process. You would think this current system is a tremendous injustice to a petitioner, the community and mostly to the USA.

The agency should also provide me with a senior experience NRC executive...where his job is to serve a petitioner. Her job is to help me with this NRC process...explain to me in a high level position way what is going on with my issue and figure out how to get the information I need ...she is to be tasked with being my inside the NRC advocator. She would be like my special NRC lawyer...

I honestly think this would make the industry more stronger and resilient...

Sincerely,

Mike Mulligan

Hinsdale, NH

Steamshovel2002@yahoo.com

They offer me no evidence or proof it safe...all you got is officials looking a paperwork and they saying its is safe. How much experience to they have with this...how many impeller pieces have been stuck between the skirt and vessel.

 Palisades 2.206 Petition - OEDO-14-00145 - MF3608

Mr. Mulligan, I have been assigned as the Petition Manager for the 10 Code of Federal Regulations (CFR) 2.206 petition, you submitted to the Nuclear Regulatory Commission (NRC) on March 5, 2014, regar

To Me

Today at 1:33 PM

Mr. Mulligan,

I have been assigned as the Petition Manager for the 10 Code of Federal Regulations (CFR) 2.206 petition, you submitted to the Nuclear Regulatory Commission (NRC) on March 5, 2014, regarding your concerns about various issues related to equipment failures and operations at Palisades Nuclear Plant (Palisades). You also expressed concerns with NRC inspection activities and the NRC’s reactor oversight process.

Section 2.206 of Title 10 of the Code of Federal Regulations describes the petition process – the primary mechanism for the public to request enforcement action by the NRC in a public process. This process permits anyone to petition NRC to take enforcement-type action related to NRC licensees or licensed activities. Depending on the results of its evaluation, NRC could modify, suspend or revoke an NRC-issued license or take any other appropriate enforcement action to resolve a problem. The NRC staff’s guidance for the disposition of 2.206 petition requests can be found in NRC Management Directive 8.11, which is publicly available.

Because you specifically requested in your letter that the NRC take different enforcement actions as described in your petition, including your request for immediate actions to prevent the Palisades plant from restarting (i.e., Items #6 and #10 in your letter), your request was referred to the 2.206 process. The 2.206 process is separate from the allegations process; the latter which affords individuals who raise safety concerns a degree of protection of their identity. In the 2.206 process, all of the information in your letter will be made public, including your identity.

On March 14, 2014, your request for immediate action to prevent Palisades restart was reviewed by the members of the Petition Review Board (PRB), which includes staff from the NRC’s Office of Nuclear Reactor Regulation (NRR), staff from Region III, and the NRC resident inspectors at Palisades. After thorough review and discussions, the PRB reached a general consensus that there were no safety significant concerns to prevent the plant from restarting as scheduled.

The NRC has reviewed the licensee’s evaluation of the impeller piece fragment within the reactor vessel and concluded that it does not pose a threat to the reactor and other plant components. Additionally, the licensee replaced all of the 45 Control Rod Drive Mechanism (CRDM) housings prior to plant startup. Please see NRC ADAMS document ML14073A612.

Based on the review of the licensee’s evaluation related to the stuck impeller piece and replacement of all CRDM housings during the refueling outage, there were no safety significant concerns to prevent the plant from restarting as scheduled. Your request for the immediate action of shutdown of Palisades and other Entergy Plants did not have the adequate bases.

In accordance with NRC Management Directive 8.11 (which I have attached for your reference), you have the opportunity to address the NRC PRB to further discuss your petition, either in person at the NRC Headquarters in Rockville, Maryland, or by telephone conference.

Please advise me by March 25, 2014, and confirm your agreement with NRC’s processing of your request under the 2.206 process. In addition, please advise me if you would like to address the PRB. If you would like to meet in person, I will need to schedule a formal public meeting at the NRC Headquarters. If you would prefer to address the PRB via telephone, I will also work with you to coordinate a date/time during the upcoming weeks.

If I do not hear from you by March 25, 2014, the PRB will meet internally to make an initial recommendation, after which we will offer you a second opportunity to address the PRB prior to our issuing a letter accepting or rejecting the petition.

Thank you,

Mahesh (Mac) Chawla

Petition Manager

U.S. Nuclear Regulatory Commission

NRR/DORL/LPL3-1

Phone: 301-415-8371

An NRC Commissioner's Safety Razzmatazz

March 19,2014

Barack, Harry, Ed and I have been working on this for a while. We just couldn't swallow that stupid speech below. I was charged with breaking the ice on the upcoming job change.

***And so says the Pilgrim plant spokesman today. Layers of redundant system can always paper over horrendous behavior. Redundancy is designed to minimized horrible behaior....indeed they invented fake safety systems as a justification to minimize to outsider the bad behavior of a plant.

McMahon said, “The layers upon layers of redundant safety systems at Pilgrim are among the many reasons why the safety of Pilgrim remains at a high level” and said the plant is working on improving its safety systems after recent downgrades

Things are going to change...

US NRC commissioner Magwood to depart for OECD Nuclear Energy Agency

Washington (Platts)--19Mar2014/103 pm EDT/1703 GMT

William Magwood is leaving the US Nuclear Regulatory Commission to become director general of the Organization for Economic Co-operation and Development's Nuclear Energy Agency in September, NRC spokesman Eliot Brenner said Wednesday.

Originally posted on March 13, 2014.

Bottom line, safety is what the congressional campaign coffers says it mean. It is nothing about science and engineering...

 
Basically, safety is an acceptable accident up to and including a Fukushima accident...

An accident where no radiation hurts anyone, but the accident causes great harm to the USA...

It is the safety philosophical rationalization that we have so many redundant safety systems that nothing matters anymore. Controlling licencee behavior doesn't matter anymore because we are so safe. 

Basically, campaign contributions makes the nuclear industry one of the untouchables!

Yet, we got another governor requesting the NRC to shutdown another nuclear plant (Pilgrim) because increasingly the NRC is found to be untrustworthy and dishonest...


March 12, 2014

CONTACT: Office of Public Affairs, 301-415-8200

“The Seven Pillars of the Nuclear Safety Future”

William D. Magwood, IV, Commissioner

U.S. Nuclear Regulatory Commission

March 12, 2014 It has been another eventful year at the NRC. Since RIC 2013, the Commission has instructed staff to develop a new rule to consider vent filtering strategies and assure contaminate integrity during severe accidents and agreed on a draft rule to risk-inform low-level waste disposal. We have launched an enhanced policy statement regarding our relationships with tribal governments and responded comprehensively to court decisions related to high-level waste.

In the past year, I have walked on the basemat rebar for the first new nuclear power plant to be built in the United States in a generation. I have also borne witness in a control room as the first U.S. nuclear power plant to be closed for purely financial reasons was powered down for the last time.

In the past year, I have addressed members of Japan’s Diet, the Premier of Taiwan, and Ministers in Indonesia to espouse the principles of safety culture and regulatory independence. I have met with scores if not hundreds of young engineers to highlight the awesome personal responsibility each and every one of them has as a member of the nuclear community.

It has been another busy year for all of us at the NRC - but it is only one of many since the Energy Reorganization Act was enacted 40 years ago this coming October. But as varied as our activities have been over the 12 months, they all converge upon a single, clear concept—that the NRC exists to assure nuclear safety.

Nuclear safety is why the NRC was created. Out of the great accomplishments and great controversies of our predecessor agency, the Atomic Energy Commission, the NRC was formed to provide a clarity of voice, a singularity of purpose, and an existential focus on nuclear safety—or, to be more precise, to assure that “the utilization or production of special nuclear material will be in accord with the common defense and security and will provide adequate protection to the health and safety of the public.”

This phase appears in section 182 of the Atomic Energy Act of 1954, the legislation that provides the core of our authorities. The Atomic Energy Act, as far-reaching and comprehensive as it is, is a haiku in comparison to the enormous bills manufactured by Congress today. While a creature from the depths of the Cold War, the provisions of the AEA remain the subject of active discussion and—despite many amendments over the decades—its foundational principles remain in effect. 

But how we interpret and apply those principles has evolved considerable since the Act became effective 60 years ago this coming August. How the broad authorities bestowed by the AEA in the era of Eisenhower and the “Say Hey Kid” are made manifest in the age of Obama and “Sid the Kid” reflects many other laws passed by Congress, many court decisions, and decades of regulatory experience and precedent.

The NRC is built upon thousands of experiences reflected in guidance and procedure. This is reflected in the inculcated culture of the organization, the evolving work practice of generations of staff, and the decisions made by the thirty-three people who have served as NRC Commissioners. The result is not simply a regulatory framework, but a collected wisdom.

In the Book of Proverbs, it is written that “"Wisdom hath built her house; she hath hewn out her seven pillars." Our house is based upon pillars of wisdom that reflect what we have learned and what we continue to learn. Our regulatory framework rests on the pillars hewn out over decades. But this wisdom is not static and it has never been. Our understanding evolves with experience and the ongoing commerce in ideas. Thus, while we must apply our current foundations to prepare for the future, our greatest challenge is to allow those pillars to shift without bringing the entire regulatory edifice to the ground.

Among the pillars that support the NRC’s overall framework, is the understanding that narrow purpose has it is own power. Part of the reason that NRC was created was to address public concerns about the scope and power of the Atomic Energy Commission. While the NRC’s role and powers are bounded by walls and barriers established over decades, the resulting framework, though it serves us very well, is complex even to those of us who live with it every day. For the public, it can be opaque and downright confusing.

For example, when the average person learns that a radioactive material called “tritium” is leaking from a nuclear plant into the groundwater, it is likely she would expect the NRC to take quick action to stop it and punish those responsible. Instead, she learns at a public meeting that NRC is a safety regulator, not an environmental regulator. Further, the NRC says the leak is not an indication of a problem with the plant’s safety systems and scientific analyses shows that it poses no hazard to public health. Therefore, NRC has no basis for action.

In other cases, members of the public ask NRC to weigh-in regarding one technology or the other—fuel cycle technologies, storage systems, and some question whether NRC should allow a utility to build a nuclear power plant at all if, for example, wind power is a viable option. In such interactions, the bright line we at NRC see between our role as a safety regulator and decisions related to national energy policy can appear murky and inexplicable to people outside the agency.

These limitations sometimes appear frustrating—even to many people inside the agency—but they serve an important principle. Vince Lombardi once said that “success demands singleness of purpose.” We take action only when it is relevant to our imperative to protect human health. We leave to Congress the decision whether to restrict or encourage a particular technology—as it has done, for example, with regard to the use of HEU for medical isotope production. Our singleness of purpose focuses our regulatory scope and it separates regulatory decisions from policy decisions.

Ironically, the most intense consternation is sometimes found in the attribute for which NRC is perhaps most widely admired around the world–our rigorous, disciplined process for making regulatory decisions.

When a proposal is made to change our requirements, we first consider whether that change is needed to ensure the adequate protection of public health and safety or to assure accord with the common defense and security. This has occurred in the past, such as when NRC responded to the terrorist attacks of September 11, 2001.

But these developments are, thankfully, quite rare and unusual. It is far more common that proposed changes do not address matters that challenge our “adequate protection” threshold. Instead, it is far more common that such changes provide more incremental benefits. If a proposed change is not in response to an issue of adequate protection or does not raise unaddressed concerns of common defense and security, NRC then engages in a “backfit” analysis to determine whether the resources required to implement the change can be justified by the safety benefits it provides. We do this as quantitatively as practical, but there is considerable judgment and debate involved in this process as well. We saw this very recently as the Commission considered a staff proposal regarding the filtering of containment vents.

Clearly, there are many observers who feel quite strongly that matters like these should not be decided by a cost-benefit analysis. Few other countries apply such an approach, and it has been argued that backfit analyses place the financial interests of industry over the safety of the public. In my view, this is an uninformed opinion.

The organizational and legal traditions in the United States are very different from those of our friends overseas. In many countries, for example, nuclear power plants are directly or indirectly owned or otherwise controlled by national governments. U.S. nuclear power plants are almost entirely the privately-held assets of commercial companies. In our legal tradition, private companies have rights that are in many cases similar to those of individuals. Commercial companies have an expectation that requirements will not be imposed upon them without good cause and due process. Our disciplined approach supports this tradition.

But more to the point, a disciplined approach allows us to focus both NRC and licensee resources on the issues of safety significance. When everything is significant, nothing is significant. Management attention, engineering talent, and, yes, financial resources can be spread too thin and too ineffectually. When this occurs, safety is not enhanced, it is weakened. Our quantitative, disciplined approach reflects this understanding.

I am not sympathetic to the concern I’ve heard from some people that the Backfit Rule makes it too hard to put new requirements in place. It should be hard. It forces us to question ourselves about what is truly needed for safety and avoid taking steps just because they may be popular or politic. At the end of the day, if there is a matter that appears to be needed for safety but doesn’t survive a cost-benefit analysis, the Commission has the authority to use its judgment to impose any requirements it finds necessary. The order issued in 2012 to enhance the instrumentation in spent fuel pools serves as a good and recent example.

The Commission structure itself is a vital pillar of our safety infrastructure. I’m sure some people hate it—five people not under the direct thrall of the usual Executive Branch structure.

Independent at inconvenient times. Sometimes a bit deliberate. Occasionally in disagreement with the staff. Occasionally in disagreement with itself.

But as I’ve noted in the past, the Commission structure, which involves intensive, informed debates among five individuals with very different backgrounds—for example university professors, nuclear submarine commanders, Congressional staff, the occasional sage—provides an excellent mechanism to reflect society’s evolving view as to what constitutes adequate protection. After four years in the center of this process, I think it is a far better approach to making important, complex decisions than leaving these matters to a single political appointee.

Nevertheless, I’m sure there are many who think we get it wrong. Since I’ve been on the Commission, we have had vigorous debates about worker dose standards, containment vent filtering, and most recently spent fuel pool safety. It is rare that everyone is satisfied with judgments on such contentious issues. But the process we apply is a disciplined one that assures consideration and evaluation of all the relevant information available to us. And, I should say, it is my opinion that in every case, we have reached an appropriate result that is protective of public safety and security.

All that said, we are not perfect. Humility is, even for sages, a core attribute of a good nuclear safety culture. As such, we must be able to change and revise our most fundamental pillars should experience, knowledge, or the availability of new methods, tools, or technologies compel us to do so. Ignoring the call for fundamental change is as bad as leaping to change for the sake of change or the vicissitudes of fashion.

As a regulatory organization, we value stability. And our licensees value stability and predictability. Yet one the most important pillars of NRC’s success to date has been our ability to evolve. SALP gave way to the ROP. Part 50 yielded to Part 52. It is my belief that the next major step in our evolution is the adoption of a strategy based upon risk-informed, site-specific regulation.

If we’ve learned nothing else over the years, it is that each nuclear power plant is a unique creature. In the United States, in particular, most plants are unique in design. They have wide variances in operating history and in the modifications incorporated over the years. As my colleague, Commissioner Apostolakis stated earlier, “risk contributors are plant specific, even for sister units.”

Moreover, American manifest destiny has bestowed upon us a country with swamps and deserts, plains and mountains, forests and tropics,

and we have nuclear power plants in most of these environments. Each site has unique characteristics and hazards that must be understood and addressed by plant design and operation.

The NRC staff does a good job of recognizing the different issues and features of each plant as it seeks to implement our regulations. But the fact exists that the agency issues and prioritizes regulatory actions on an industry-wide basis. It is not quite “one size fits all,” but it is a close relative. We have taken diminutive steps toward site-specific prioritization, for example in implementing seismic and flooding reassessments. Staff has prioritized plants in groups to be reviewed over the come months. This approach allows the NRC to prioritize the plants facing the most challenging seismic and flooding issues and enables us to apply our resources in a logical and effective fashion.
But this barely scratches the surface of the benefits that can be obtained by designing the regulatory agenda on a plant-by-plant basis based, to the extent practical, upon a quantitative understanding of risk. Adopting such an approach would allow the resources at each plant to be focused on the safety issues of highest significance for that plant and get them done more quickly and more efficiently.

Clearly, making this change will be difficult. It will require enhanced PRA tools and models and it will require research to develop the facts and data to support those models. It will require a shift in mindset in both the industry and NRC that embraces more fully probabilistic approaches. It will also require a willingness to make the up-front investments in order to realize long-term benefits.

However, it is vital that we never lose the perspective that plant operators are responsible for safety—not the NRC. There is no legislation that states it, but operators must take the principal responsibility for the safety of their plants. This understanding informs all we do as the regulator and the regulated.

A licensed operator recently asked me an interesting question: “Would nuclear power plants be operated safely if NRC did not exist?”

This is the question we should all ask. The answer should be ‘yes” but I doubt that anyone here today would give this reply without hesitation. Just as the plants differ, so do the companies that own and operate them. Some are, quite frankly, stronger than others. If this were not the case, we would not have and need an INPO.

That is not to suggest that any operator would, left to its own devices, run a plant in an irresponsible manner. But without a regulator, what additional pressure would plant managers feel from boards and financial staffs? Would maintenance cycles be stretched? Would training be cut back? What would be the “safety goal” for each plant? How much risk would be acceptable?

The reality is, quite clearly, that industry needs the NRC. Where would public confidence be without a strong regulator? NRC provides a common expectation for safety across the country that all operators understand they must meet. This provides a coherent standard by which decisions regarding plant operations and investment can be measured.

But this yardstick should not become a shepherd’s crook and plant managers should not be pushed into the role of sheep led about by the NRC staff. We must not create an environment in which plant decisions are made—or not made—with solely compliance in mind rather than plant safety. When owners refuse make safety-beneficial investments in a plant unless NRC requires them, we have all failed. When plant managers forego the installation of equipment that they believe would increase the safety of their plants because the NRC staff gives little or no credit for the installation, we all need to take a long look in the mirror. Are these the outcomes we expect and want? For my part, I don’t think that they are.

Think about the practices that have evolved over the decades and the cultures we have established—both good and bad. For many of the people who regulate and operate plants today, the current balance between regulator and licensee is viewed in the context of the 35 years since the Three Mile Island accident. They have the perspective born of experience to know how to draw the lines and how they have shifted over time. 

With a new generation gaining prominence in both the industry and the NRC, the experience of the past is fragmenting into snippets of history and legend. I am very proud of the important role the Federal government in general and the NRC in particular have played in supporting nuclear technology education in the United States. What we have accomplished has helped prepare us for the changing of the guard and assured that the most important pillar of our nuclear safety infrastructure—highly trained people—will remain strong for many years to come. That is a success story.

But this new generation of engineers and scientists, as quick and bright as they are, lack the experience of the days when dozens of new plants came on line and plant transients were all too common. The experience of those who managed NRC and the industry through those times is fading from the scene, never to be replaced. Even with NRC’s excellent training programs, this is a reality that cannot be evaded.

However, these young people will also bring new ideas, new energy, and new approaches as they grow into positions of increasing responsibility. Even now, in plants across the country and in the halls of the NRC, this new generation pushes us into the future. I imagine they are sometimes frustrated by the structures and practices of the ruling generation. As T.E. Lawrence wrote in his memoir Seven Pillars of Wisdom: A Triumph, “Youth could win, but had not learned to keep, and was pitiably weak against age.” But I say to them, be patient. Your time is coming soon and the responsibility for nuclear safety will pass to you all too quickly. Your challenge is to be ready to accept the responsibility when that time comes.

One of the greatest aspects of the RIC is the participation of so many of our friends and colleagues from around the world. Welcome to all of you and thank you for attending this year’s conference. Your presence today is no longer a luxury or a convenience. It is a vital necessity.

I’ve often reflected on that moment, during the signing of the Declaration of Independence when Benjamin Franklin famously remarked “We must all hang together, or assuredly we shall all hang separately.” This comment applies to many things in life, but even Franklin could never have forecast how well it applies to a group like the 3100 people in this hall today.

Nuclear power is a global undertaking and we are in this together. We are married to each other. We are held hostage by each other. We are each other’s best friends and worst enemies. We are at once buyers and suppliers. We are teachers one day and students the next. The relationships and cooperation we share are part of the modern foundation of nuclear safety in all of our countries. We must seek to expand and extend them.

Thus with the engagement with our colleagues across the globe; our focused mission and disciplined processes; our Commission structure; and our ability to change when change is required, we will go forward. By reinforcing the understanding that operators—not regulators—are responsible for safety and by continuing our investment in the next generation, the pillars are in place to assure that the Nuclear Regulatory Commission will continue its impressive success and be prepared for the unknown challenges that the future will bring.

When the Atomic Energy Act became law 60 years ago, no one could have imagined the breadth and diversity of nuclear power and nuclear regulation as it exists across the world today. Our challenge is to find a way to make that diversity a strength from which to build a brighter, safer future for the publics we all serve.

Epic Reform of the NRC this Year: Magwood Out

Note: I am not busy right now and I would like to be considered for a NRC commissioner!

This could be epically historic...they wouldn’t need a filibuster of 60 votes in the senate with a NRC nomination for the first time in the history of the Nuclear Regulatory Commission. All it would take is 51 votes and we have a least 55 Democratic senators.

Just saying, these agency leaders are uncontrollable....

Harry Reid Senate Marjory leader:

"In an interview with the Huffington Post after Jaczko's resignation, Reid lashed out at Magwood, calling him "a treacherous, miserable liar" who had deceived Reid about opposing Yucca Mountain. "He's a first-class rat ... (and) a tool of the nuclear industry," Reid said."

Senator Markey:

..."said the four commissioners had attempted a coup against Jaczko"

So democrats Magwood and Apostolakis get replace by pro safety experts instead of industry lackeys.

If there is a god out there, now it the time for a significant accident but no release.

US NRC commissioner Magwood to depart for OECD Nuclear Energy Agency

This is the way a president fires a NRC commissioner...the president promotes him out.

Washington (Platts)--19Mar2014/103 pm EDT/1703 GMT

William Magwood is leaving the US Nuclear Regulatory Commission to become director general of the Organization for Economic Co-operation and Development's Nuclear Energy Agency in September, NRC spokesman Eliot Brenner said Wednesday.

Brenner did not say how much longer Magwood will remain on the five-member commission before departing for his new position in Paris.

NEA's mission statement says its purpose was "to assist its [31] member countries in maintaining and further developing, through international co-operation, the scientific, technological and legal bases required for a safe, environmentally friendly and economical use of nuclear energy for peaceful purposes".

NEA also said it seeks to "provide authoritative assessments and to forge common understandings on key issues as input to government decisions on nuclear energy policy and to broader OECD policy analyses in areas such as energy and sustainable development".

Magwood said in a statement: "It is a tremendous honor to have been the U.S. Government's candidate for this position and to have been selected as the seventh Director General to lead the NEA since it was formed in 1958. I have especially appreciated the strong support and encouragement I received from senior officials of the Administration to take on this assignment. When I join the NEA in September, I will take with me the vital lessons I have learned from my time at the finest safety regulator in the world -- the U.S. Nuclear Regulatory Commission."

A senior NRC official said Magwood "has a number of commitments in the coming months as a commissioner. He is going to fulfill those before deciding on a departure date from the NRC." The comment was on background because the official is not authorized to discuss the timing of Magwood's departure.

Magwood, a Democrat, was appointed to NRC by President Barack Obama in April 2010, and was later reappointed for a five-year term ending June 30, 2015. He previously served seven years as director of nuclear energy at the US Department of Energy.

Magwood has also taken an interest in moving NRC's safety regulation of US nuclear power plants toward a more risk-informed basis -- that is, grounding more of the agency's safety requirements on insights from tools such as probabilistic risk assessments, computer models that calculate the probability of various accident scenarios.

In October 2011, Magwood and the other three commissioners -- George Apostolakis, a Democrat, and William Ostendorff and Kristine Svinicki, both Republicans -- said in a letter to then-White House Chief of Staff William Daley that the behavior and management practices of then-NRC Chairman Gregory Jaczko, a Democrat, "have become increasingly problematic and erratic...[and are] creating a chilled work environment at the NRC".

The letter was released that December by the Republican-controlled House Oversight and Government Reform Committee.

Later that month, then-US Representative Ed Markey, a Massachusetts Democrat for whom Jaczko had worked as a staffer, said the four commissioners had attempted a coup against Jaczko by sending the letter to the White House because of the chairman's strong stance on safety issues. Jaczko denied the allegations but resigned in May 2012.

Apostolakis's term expires June 30, so the Obama administration will need to nominate two new commissioners in coming months. The Senate must approve those nominees. Apostolakis would not say last week whether he was interested in serving another term on the commission.

Palisades 2.206 PCP Broken Impeller: Emergency Request to Stay Shutdown

The Palisades Saga

March 21:

Today at 11:37 AM

Mr. Chawla, 

I don't agree with the agency's decision on the impeller. I'd like to speak to the PRB by telephone please.

But, good job on the CRDMs! 

Can i speak to agency experts about the Palisades PCP broken impellers...can they be "up" on the history of PCP impeller damage at Palisades and the industry? 

I am waiting to see the NRC PCP impeller report concerning this on Adams...what is your proof that it is safe? I am particularly interested in IN 85-03. 

Thank you,

Mike

March 17: I am sure Palisades and the NRC got twenty pointy headed nuclear safety engineers each locked in a room for weeks poring over the paperwork and pictures. They call that safety. I call actual testing and experiments as safety.

The NRC has validated my scenarios as valid in my 2.206...the head corroding and blocking off flow to the assemblies. I certainly know my way around a PWR core and vessel.

"The NRC conducted an in-depth, independent review of the plant analysis of the impact the piece of metal within the vessel may have on the reactor vessel and fuel safety."

 Here is my criticism of their plan.

The Palisades Cracked and Detached PCP Impeller Saga 

 So the agency is answering me and validating my scenarios in my 2.206.

"The NRC conducted an in-depth, independent review of the plant analysis of the impact the piece of metal within the vessel may have on the reactor vessel and fuel safety."

Originally published on March 5
March 11

Honestly, this is what would make me conformable. Make a mockup of the core...then get a size assortment of impellers pieces. Say measure the  stuck piece as best as can...say the accuracy is plus or minus 10%. You then get something like three pieces of of the impeller pieces, one the estimated size and shape, then a  piece 10% bigger and another 10% ssmall. Then bang the pieces around in all kinds of core flows. In the mock up, you could carefully monitor where the pieces go and how they behave.  I am certainly not a engineer...but you get the idea.   

So it is in to  the NRC...I misdated it as of yesterday.

Another area of increased non transparency is the leaking fuel pins and damaged fuel tubes. It would be legal today with half the pins in the core being  pierced and fuel pellets are rattling around in coolant:)  

They have administratively reduced the reportability requirements with damage fuel.

Honestly, I am beginning to wonder if Palisades would intentionally damaged a few fuel pins. It would kick up to radioactive dose rates all over the plant. Palisades could then use the high dose rates as justification for reducing half their maintenance and testing. I bet you they could cut the outage time in half! We know the NRC would buy into this craziness.

Personally, I think we have entered a very dangerous period within nuclear power. The idea that a lot of insiders and outsiders fear that one little "huff and puff of a little wolf’s breath" could knock prominently Palisades off the line. It is plain as daylight that a lot of people and news media around Palisades fear one more article could knock Palisades off the line.   

Everyone is pulling their punches fearing their utterance will kill 1000 or more jobs...  

March 5, 2014

Mr. Mark A. Satorius

Executive Director for Operations

U.S. Nuclear Regulatory Commission
Washington, DC 20555-0001

DEFINITION OF NUCLEAR SAFETY CULTURE

Nuclear safety culture is the core values and behaviors resulting from a collective commitment by leaders and individuals to emphasize safety over competing goals to ensure protection of people and the environment.

TRAITS OF A POSITIVE NUCLEAR SAFETY CULTURE

Experience has shown that certain personal and organizational traits are present in a positive safety culture. The following are traits of a positive safety
culture:

• Leadership Safety Values and Actions—Leaders demonstrate a commitment to safety in their decisions and behaviors.

• Problem Identification and Resolution—Issues potentially impacting safety are promptly identified, fully evaluated, and promptly addressed and corrected commensurate with their significance.

• Personal Accountability—All individuals take personal responsibility for safety.

• Work Processes—The process of planning and controlling work activities is implemented so that safety is maintained.

• Continuous Learning—Opportunities to learn about ways to ensure safety are sought out and implemented.

• Environment for Raising Concerns—A safety conscious work environment is maintained where personnel feel free to raise safety concerns without fear of retaliation, intimidation, harassment, or discrimination.

• Effective Safety Communication—Communications maintain a focus on safety.

• Respectful Work Environment—Trust and respect permeate the organization.

• Questioning Attitude—Individuals avoid complacency and continuously challenge existing conditions and activities in order to identify discrepancies that might result in error or inappropriate action.

(The problem I have with “commensurate with their significance” is the agency and nuclear industry exaggerates their granularity with seeing safety significance reality boundary...it is a political statement. Nobody here has a god’s eye perfect view of what engineering reality is...the demarcation between safety and safety insignificant. You can’t even anticipate or predict with all the scientific and engineering tools known to mankind when a PCP impeller or CRDM will crack with accuracy. My proof of this is within this outage and the repetitive nature of these events.) 

Dear Mr. Satorius,

The links on the below are all on my blog:

http://steamshovel2002.blogspot.com/2014/03/the-amazing-collaspe-of-palisades.html

The research concluded that the cause of the failures is fatigue-related effects from the operation of the pumps in conditions beyond the maximum flow rates and below the minimum net positive suction head recommendations as described in the UFSAR and other design documentation.

I’ll just say, San Onofre came to the end through many years of horrendous maintenance and operational problems. The last straw came from poor maintenance and bum engineering associated with the new generators. I think if San Onofre had a sterling NRC and public record...they would have survived.

Do you even want one nuclear plant operating in the USA if the agency allows a corporation to operate a nuclear plant in such a sloppy manner...indeed the NRC's ROP accommodates this sloppiness over and over again?

SUBJECT: PALISADES NUCLEAR PLANT INTEGRATED INSPECTION REPORT 05000255/2012003

The inspectors identified a finding of very low safety significance and associated NCV of 10 CFR 50 Appendix B, Criterion III, Design Control, for the failure to operate the Primary Coolant Pumps (PCPs) in accordance with their design operating criteria. In October 2011, a slight rise in vibration levels on the ‘C’ PCP occurred and was sustained for approximately 24 hours. This was followed by a short spike in vibrations and a return to a lower stabilized value than what had been previously observed. Investigation by the licensee revealed it was likely a piece of an impeller vane which had deformed and broken free. Based on a review of operating experience associated with impellers and further licensee investigation, the inspectors concluded that the PCPs had been operated outside of their license/design basis as stated in the Updated Final Safety Analysis Report (UFSAR) with regard to minimum net positive suction head and maximum flow. Further, based on impeller-like pieces found in the reactor vessel in 2007 (which an apparent cause stated likely came from a PCP), and an operating history which indicated past occurrences of vane breakage and degradation, the inspectors concluded the licensee had the ability to foresee and correct the condition affecting the PCPs prior to the release of a piece in October 2011. The licensee entered the issue in their Corrective Action Program (CAP) as CR-PLP-2011-5744 and performed additional research into the phenomena leading to the impeller degradation. The PCP operating sequence was changed, an Operational Decision Making Issue was implemented, and efforts to explore further procedural changes are on-going to mitigate degradation of the impellers.

Criminal and malicious facilitative assumptions never backed up by science and evidence...judgments dictated by self-interest and massive political corruption. The utilities get to write the rules and control the agency.
 

2012-003: Investigation by the licensee with the assistance of outside consultants concluded it was likely that a piece of the ‘C’ PCP impeller deformed and broke free. There was no indication of degradation to the primary coolant system or reactor core components as a result of this postulated failure. NRC inspectors, including experts at the Offices of Research and Nuclear Reactor Regulation (NRR) reviewed the data gathered by the licensee and concluded that the pump was safe to operate until the refueling outage in April 2012 with the monitoring plan that the licensee had put in place.

This is a huge piece of metal.

The metal is 5 inches by 12 inches long..

"Lindsay Rose, spokeswoman for Entergy Corp"...why do we let these officials speak to us so plausibly stupid? Why are they so ill prepared with the history of the issue when they talk to the public? I think this is purposeful. Why aren't they technical people talking to us, instead of highly paid corporate spokesmen paid to talk stupid to us! This was intentional she didn't have the history on the impellers.
 

Rose said she did not have any information about when the metal piece might have broken off the impeller, which has been replaced. An impeller is a rotor that is used to pump water within the reactor.

This exactly like the "safety injection refueling water tank", which took them decades of leaks and half ass fixes before they discovered the tanks weren't constructed as designed (constructed poorly). Don't forget about the massive self-destruction of the  Palisades CRDMs they are dealing with right now. The repetitive nature of flaws, cracks, leaks and shutdowns...the obscene nature of the exact same NRC violations and failed revolutionary alloy designs repeated over and over again derived from poor quality maintenance and plant operations! The impeller weld job from the Walmart Superstore Automart known to be a lessor quality than the Primary Coolant initial design requirements.
   

The NRC accommodates plant and corporate destructive behavior...they aren't in the game of mandating a change of bad behavior! The NRC isn't in the game of picking up the easily detectable early stages of bad behavior...then turning it into good business behavior towards the better interest of the USA and our communities. Believe me we get it, this result is a political congressional and presidential prerogative.

The licensee identified impeller cracking had been observed at Palisades on several occasions since 1984, when the pumps had been removed for inspection and refurbishment/replacement.  

How many total pieces? Obviously they falsified past investigations and searches for broken impeller pieces...knowing the current piece was unrecoverable or not removable. At worst, they were incompetent with past searches.

Additionally, pieces suspected to be from impellers were discovered in the bottom of the reactor vessel in 1984 and 2007.  

The broken impeller and cracked CRDM are terrible and dangerous news...but all the things that has happened in last four years at this plant are much worst?
 

Epic non-conservative judgments. It is systemic engineering certainty and uncertainty gaming. Why didn't the agency stop Palisades...make them inspect all the PCP impellers considering all this history upon the first detached impeller vane? Why wasn’t this reportable to the public. What else is not openly disclosed to the public.  The 2011 Red Finding yellow finding spoke of endemic and habituated non conservative judgments (a pattern). They are doing the same engineering and regulatory gaming with the massive and repeated CRDM cracks and the broken off impeller vanes seemingly with the NRC 's permission...the yellow finding medicine through 2012 absolutely did not take hold. It was all a fake phony facade.

I'll put it in the grid and ISO perspective. Exelon is threatening to shut down an assortment of nuclear plants within a short period of time because of low ISO market prices of electricity and unfair competition from corrupt green electricity. Palisades is situated in the same market and undergoing the same pressure. Well, except it is a merchant plant.  The NRC is severely pulling their punches because they know Palisades is so economically vulnerable. Why didn't we ever know what the true motives with the decision the NRC and Entergy makes? Why is everything always hidden from us? Why is our electricity market so Soviet style, when we are supposed to be the most open society is the world?
 

Approx. May 2012: In response to the discovery of two pieces that resembled the PCP impeller composition during reactor vessel inspections in 2007, the licensee conducted an apparent cause analysis. The conclusion was that the pieces were most likely from the ‘D’ PCP. Additionally, the analysis explored the history of Palisades’ PCP impeller conditions which included repeat occurrences of cracking having been identified and an instance of "heavy recirculation damage," which rendered an impeller unfit for continued use. The pump manufacturer, Flowserve, also released a Tech Alert due to the Palisades PCP vane cracking history. The apparent cause analysis implied that the pieces were fatigue generated and that additional vane breakage was possible. Despite this, the PCPs were not declared as non-conforming nor were any compensatory measures taken. When the ‘D’ PCP was later inspected after removal during the 2009 refueling outage, it did not have any pieces of impeller missing. Inspections of the other PCPs, which were recommended in the apparent cause and had been planned to be executed if the ‘D’ PCP was not the source of the 2007 pieces, were cancelled. The cancellations were based, in part, on thoughts that the pieces may have originated elsewhere. However, vessel inspections done in 2007 revealed no deficiencies that would infer the pieces were generated somewhere within the reactor vessel, and the 2007 apparent cause analysis had essentially ruled out other sources.

Come on, the inspection was cancelled because they were trying to save a few pennies by not lengthening an outage. The pressures on making a short refueling outage is going to be very damaging to the USA someday...

Right, the above is engineering certainty/uncertainty language gaming...found impeller pieces in 2007, opened one pump in 2007, found no damaged impeller, assumed they found nothing broken in the primary piping system and core...thus all the other pumps must have no broken impeller. Conservative judgment would consist of finding one piece of impeller...then opening up all the PCP pumps and replacing all the impellers with good quality impellers... matching up the broken pieces with impellers.

Remember, I talked about beautiful science and technology. Why the fixes coming out of the 2012 NRC inspection didn’t put an end of with vane damage. They inspected the impeller this outage and then found this huge piece of metal at the bottom of the vessel. It seems like the opened up pump didn’t have the damaged impeller. How do we know right now there is not another broken impeller in a non-inspected pump? Obviously the pump is a defective design...not good for the duty intended. We still don't know why Palisades operated this pump outside the manufacture recommendations and plant designs.

I try to use science and engineering to anticipate problems and fix them early...Palisades and the NRC uses science and engineering to justify not fixing defects and running equipment irresponsibly. Science is just a tool...you can use any tool to do good or evil. Or just plain “bullshit” the outside with disconnected scientific and engineering talk and rationalizations. Dressed up disconnected corporatese public relations talk.  It is just a choice! 

Rose said the impeller piece was from one of the plant's four main coolant system pumps. That impeller was recently replaced during this outage, she said.
 

Personally in the below, I'd be worried PCP seal damage with a damaged off balanced impeller...that is in the accident studies with the largest risk to the community. I wouldn't trust the accuracy of the installed vibration detectors.
 

Any good corporate citizen would immediately recognize weld repairing a safety related nuclear pump impeller in a high temperature environment is just plain crazy science and engineering talk. Where is the NRC in establishing standards! Maybe the pump is so obsolete they didn’t have new impellers in stock? Why has the NRC allowed Entergy to weld repair PCP impellers? Ah, the codes are god...you can’t question the store bought corporate engineering codes.

The licensee noted, based on metallurgical examination of a previous fragment, previous pump inspection findings, and the mechanism by which the cracks propagate, that weld-refurbished impellers were particularly susceptible to degrading to a point where a piece could be released.

Entergy always knew where to look.
 

Additionally, pieces suspected to be from impellers were discovered in the bottom of the reactor vessel in 1984 and 2007.

I think this all is a broad corporate business philosophy...Entergy is Systematically Destroying Nuclear Plants through a Run-to-Failure Philosophy. Here is a new Pilgrim nuclear plant NRC inspection report. The agency speaks of non-safety component's run-to failure philosophy. It does get you wondering, will the non-safety equipment run-to-failure-philosophy cause the public to lose faith in the safety of a plant? Does Entergy even care?  It might be legal to the corporatized NRC, but it is not be acceptable to the public?
 

New Pilgrim Plant inspection-The following observations have been noted by the inspectors: SRV performance was a driver for several down powers and forced outages in 2012 and into 2013; a number of unplanned down powers and shutdowns were the result of non-safety-related equipment failures; it appears that non-safety-related equipment that was characterized as a run-to-failure is starting to reach the end of their service life and can likely become contributors to such events.

Do you want anything nuclear to ever run-to-failure? Are these guys so smart with completely understanding the complexity of the reality inside these plants? If they did, these guys would operate these plants without blemish. We wouldn't be here today. They think we can see a god’s eye granularity...or at least they pretend to speak to us outsiders that way.
 

This is a prime example with the NRC inspection, licensee notification system to the public and the ROP. What is the agency covering up? Why hasn’t every flaw or crack in PCP impeller thoroughly covered in a Licensee Event Report? Why wasn’t all the broken off vanes thoroughly covered in a LER. Why wasn’t every flaw or worst in an impeller thoroughly covered in an inspection report? What you hide, you repeat; what you openly disclose, you fix and begin repairing the organization.
 

Further, this is questions if the NRC are selectively releasing troubling information at all the plants. That is, what information disclosures are required and what info actually gets released? It invalidates the ROP and the trustworthiness of the NRC. In an open democracy like the great USA, so they say...there should have been a public document trail from the moment the first impeller flaw showed up in the NRC and Entergy. I get the NRC has the power of kings...they get to decide what rules are valid for the agency and utility irrespective of the rules on the brooks. The rules are secretly situational for the agency.  This is all razzmatazz corruption up with phony scientific and engineering language.
 

The worst agency sin of all, why wasn’t there a follow up report on “NRC Enforcement Policy (NCV 05000255/2012003-02, Operation of Primary Coolant Pumps Outside the Design Basis”?
 

Basically the NRC and Entergy are saying it is safe to operate these components outside their manufacturer and plant designs...even after repetitive damage. Even after the manufacturer told them to knock it off. It is self-destruction on a massive scale! The NRC allows a utility to run- to-failure safety components? This is a run-to-failure philosophy just like Pilgrim except it is actually safety related.  Are components ever designed, tested and licensed to run-to-failure...where we know by engineering how it happens? You notice the NRC never gets to the bottom of it...public democratic disclosure...the ultimate rationale or justification with why Entergy was operating these components to damage outside the manufacturer’s recommendation. Oh brother, we know why they are doing it. This looks terrible on the nuclear industry to the outsiders...they are protecting themselves through the high powered Soviet style secrecy and deceptions. They are the ones with the keys to the actual information with what is really going on.
 

The research concluded that the cause of the failures is fatigue-related effects from the operation of the pumps in conditions beyond the maximum flow rates and below the minimum net positive suction head recommendations as described in the UFSAR and other design documentation. These conditions are present when operating only one or two PCPs during reduced temperatures and pressures (typically during startup and shutdown activities). Cyclic pressure pulses and stresses are created under these reduced pressure conditions that act on the leading edges of the impellers, which can ultimately lead to vane cracking and the release of impeller fragments. The licensee noted, based on metallurgical examination of a previous fragment, previous pump inspection findings, 18 Enclosure and the mechanism by which the cracks propagate, that weld-refurbished impellers were particularly susceptible to degrading to a point where a piece could be released. Currently, none of the PCPs contain any remaining weld-repaired impeller areas (ones that did are postulated to have released pieces already). Also, at normal operating temperature and pressure, there is adequate net positive suction head on all PCPs, so these additional stresses are not present.

In response to the discovery of two pieces that resembled the PCP impeller composition during reactor vessel inspections in 2007, the licensee conducted an apparent cause analysis. The conclusion was that the pieces were most likely from the ‘D’ PCP. Additionally, the analysis explored the history of Palisades’ PCP impeller conditions which included repeat occurrences of cracking having been identified and an instance of “heavy recirculation damage,” which rendered an impeller unfit for continued use. The pump manufacturer, Flowserve, also released a Tech Alert due to the Palisades PCP vane cracking history. The apparent cause analysis implied that the pieces were fatigue generated and that additional vane breakage was possible. Despite this, the PCPs were not declared as non-conforming nor were any compensatory measures taken. When the ‘D’ PCP was later inspected after removal during the 2009 refueling outage, it did not have any pieces of impeller missing. Inspections of the other PCPs, which were recommended in the apparent cause and had been planned to be executed if the ‘D’ PCP was not the source of the 2007 pieces, were cancelled. The cancellations were based, in part, on thoughts that the pieces may have originated elsewhere.

Engineering and scientific certainty/uncertainty gaming is pernicious engineering language corruption. It is stealing community security and lying to the CEO and stockholders.  

However, vessel inspections done in 2007 revealed no deficiencies that would infer the pieces were generated somewhere within the reactor vessel, and the 2007 apparent cause analysis had essentially ruled out other sources.

In response to the October 2011 event and subsequent research conducted to better understand the phenomena affecting the PCPs, the licensee has instituted a monitoring plan, changed the preferred sequence for starting/stopping PCPs during startups and shutdowns, and has corrective actions to explore further procedure changes regarding operation of the PCPs and the resultant impact on other aspects of plant operation.

Yet here we sit in 2014 with a broken impeller and a blade stuck in the vessel. They don’t know where the broken blade came from...there is no engineering proof it didn’t come from a non inspected pump impeller. Are you absolutely sure your at power plant vibration detectors would detect every detachment?

 There is no absolutely no proof that the corrective actions coming from IR 2012003 actually fixed the problems. If the problems was so easy to fix as to the “properly sequence the RCP pumps” during heat up and cool down operation, why didn’t they do this easy and cheap fix three decades ago?  
 

Since the licensee was intending to have this non-conformance on the C pump (missing impeller pieces) the entire cycle, the inspectors (including experts at the Offices of Research and NRR) reviewed the impact of this non conformance on the PCP safety functions. Key safety functions of the pump are to provide a coolant pressure boundary and ensure an adequate coast down of flow. The review indicated there were no current safety issues with this non-conformance. The inspectors are evaluating the monitoring plan to determine its long-term effectiveness.

You get it, no intent in 2012 to inform the public and its being repeated in March start-up?

How do we know what are the forces holding the broken vane to between the reactor vessel and vessel shirt? Everyone in New Hampshire this winter knows the power of water and ice expanding and contracting. We are inundated with frost heaves and frozen broken pipes. So what about the difference of contraction between the vessel and flow skirt from 550 degrees/2250 psi to room temperature? In other words, there could be tremendous forces squeezing the broken vane between the vessel and the flow shirt solely due to the cool down. How do we know if a bolt isn’t snapped or it there is weld failure attaching the shirt to the vessel or other components? How do we even know if the cladding has been penetrated into the vessel alloy by the broken vane. How do we know if some corrosion mechanism on steroids would secretly take place at power and normal temperate? What if  this leads to a vessel penetration and then onto  a LOCA? Would it get past a vessel design max flaw leading to a vessel LOCA?   

So you tried yanking out the broken vane. What if all you did is just loosened it? The vessel and skirt re-expands upon heat-up and normal flow vibration releases the errant broken impeller vane. It then travels into a centerish high powered fuel assembly inlet and blocks off coolant flow? What if it blocks off flow to two fuel assemblies? What if we wake up one morning and two fuel assemblies have been destroyed?  Palisades and the NRC have melted down two fuel assemblies. It would be a tremendous internal release of radioactive. Most likely it will be an insignificant release of radioactivity to the outside. It would destroy the core and the operability of the plant.  Hope your steam generators are tight. It would probably take out many other plants in the USA. It would be a media circus much worse than TMI. There would be massive re-regulation.

I would characterize this off normal event as extremely complex and there is an assortment of barriers preventing everyone from seeing what is going. Palisade has once again over stated their granularity with understanding of what is going ...predicting future interactions.  These guys think they have turned water into wine again. If these palisades engineers are so good at predicting the future...why did n't they allow the impeller even crack and break off? Why didn’t Palisades and the NRC prevent the impeller damage based solely on their perfect science and engineering? These guys can’t even control and predict human behavior...why did they tolerate operating outside the plant designs? There is just so much complexity and missing science and engineering information here...the future of this is not understandable or predictable!  

Engineers make sense out of the apparent available evidence...I worry about the unknown unknowns. (http://en.wikipedia.org/wiki/There_are_known_knowns).

DonaldRumsfeld: ‘Reports that say that something hasn't happened are always interesting to me, because as we know, there are known knowns; there are things we know that we know. There are known unknowns; that is to say, there are things that we now know we don't know. But there are also unknown unknowns – there are things we do not know we don't know”.

You guys are running is the greatest “confidence game” the world has ever known (professionalism and educational). A confidence game are words and utterances by the NRC or a licensee not backed by true science, engineering or the facts. More, situational quasi science, engineering or the facts...ghost truth and evidence!

confidence game, any elaborate swindling operation in which advantage is taken of the confidence the victim reposes in the swindler.

I respectfully request the following.

1)     The NRC and Entergy hold a mandatory public meeting before start-up and disclose at the facts surrounding this. The NRC has a well-known path with only disclosing the dirty laundry months after start-up, if ever.

2)     Palisades and the NRC explain why the plant was allowed operate outside its design bases for so long. Why did the NRC allow this violation until damage show up?
 

3)     Palisades pop open every pump for an inspection...all flaws cleared up with new impeller.
 

4)     Palisades explain why they went to dangerous weld repair instead of new impellers. Please detail how all the other plants repaired their impellers...weld or new impellers?
 

5)     Request a ten million dollar fine over these events.
 

6)     Palisades is mandated to remove the broken vane before start-up.
 

7)     Please detail all activities to prevent going beyond the design basis? Has it been proven this “explored different sequencing of PCP operation during subsequent startups” has prevented further violations of the design basis?
 

8)     Please disclose all plant information and investigatory information associated the damaged impellers. Have there been any flaws post new “sequencing of the PCP” discovered?  
 

9)     Were there any Entergy internal reports or concerns made before the 2012003 NRC inspection that Entergy was operating outside it design bases? Please disclose all documents associated with this.
 

10)  Please disclose all information associated with the CRDMs flaws and crack replacement activities this outage. Request that Palisades not startup until all the CRDMs are replaced.  God help you if the eight or so CRDMs not replaced develops a leak during this next operation period. Please disclose the reasons and resource limitations preventing the replacement of said CRDMs.
 

11)  Please disclose the date and time when the broken vane was reported to the NRC.
 

12)  Is this going to be an LER or event notification...please explain why it is not reportable?

13)  I Request Palisades be returned to the yellow or red status...intensification of NRC monitoring!  This plant continues to be a very dangerous plant to the community of US nuclear plants. This plant has a recent history of excessive shutdowns, taking dangerous shortcut risking human life and plant safety (DC) and the uncontrollable intensification of component flaws, cracks and leaks. Entergy has a known run-to-failure philosophy with the NRC and it clearly has been defusing into safety systems at Palisades.

14)  Please list all the plant debris...especially metal shards and pieces discovered in the inlet to the primary side of the steam generators. Please list and explain any debris discovered anywhere in the primary system for the last ten years.
 

15)  Please replace the Primary Coolant Pumps with a design for its intended duty!

This rises to the level where the public are not being adequately apprised of the conditions of the nuclear plants. Members of the public are being systemically denied an adequate democratic process within the nuclear industry. If big and important events are being withheld from public view...then any minimal NRC process is a impossibility. I hereby declare, we are pre TMI with mandated public disclosures!   

Palisades spokeswoman Lindsay Rose tells WSJM they have "determined there will be no impact on safe operations." She went on to say the piece is separated from the fuel and the material "does not rise to the level of being reportable to the Nuclear Regulatory Commission."
 

Sincerely,
 

Mike Mulligan
Hinsdale NH
16033368320
steamshovel2002@yahoo.com