Here is the dose violation in the current inspection report. The NRC is going to jack up their attention to the to Palisades. I have been saying all along since the outage that Entergy-Palisades is in terrible condition and you need to watch them a lot more carefully. There was no reason at all to drop the yellow finding on then 2011. You really can't understand this violation until you see the context of this going back to the last CRDM housing replacement job. Why didn't this come out in May 7 outage inspection report eight months ago?
December 2, 2014: SUBJECT:PALISADES NUCLEAR PLANT, NRC INSPECTION REPORT 05000255/2014010
Preliminary White. The NRC identified a finding and two apparent violations of NRC requirements associated with the replacement of CRD housings between February 6 and March 8, 2014. Specifically, the inspectors identified an apparent violation of Title 10 of the Code of Federal Regulations (CFR) Part 20.1201, “Occupational Dose Limits for Adults,” because the licensee failed to ensure that radiation worker dosimeters calibrated to the Deep Dose Equivalent (DDE) were located at the highest exposed portion of the respective compartment, a condition of the NRC-approved method for determining effective dose equivalent external (EDEX). The inspectors also identified an example of an apparent violation of Technical Specification 5.4 “Procedures,” associated with this finding. Upon identification of this issue, the licensee suspended the use of EDEX and tungsten shield vests. The licensee re-calculated the dose received for the workers involved and updated the nuclear power industry’s dose tracking system with the revised dose results. Additionally, a root cause evaluation was initiated under Condition Report CR-PLP-2014-04683How does it come the inspection results are eight months late? Why isn't the NRC attention to Palisades immediately increased with the hopes of quickly turning their behavior when the violation first occurs? Are there a lot of delayed violations? What is the meaning of that. Obviously everyone is overwhelmed with the complexity with their declining plant and this extremely complex outage. The complete CDRM replacement job and the issues with a huge RCP impeller blade stuck the core was never planned for before the outage. They never expected to discover the amount of cracking in the CRDM housing as they did. Did the NRC not want to hit Palisades overwhelmed staff with more NRC bureaucracy in the recovery from the outage. Why can Palisades get hit with one radiation type violation, they deeply take in the meaning of the violation... then there isn't another radiation violation for a decade or more?
The reactor oversight process and it all being risk related...it just don't work properly. It doesn't prevent reoccurrences and the prevention of repeated violation. Matter of fact, it incentivises more violations and risk taking. It jacks up destructive complexity. Lets look at more NRC 2014 inspection reports for the same theme"
December 2, 2014: COMPONENT DESIGN BASES INSPECTION 2014008
This is the violation: "Based on the results of this inspection, ten NRC-identified findings of very low safety significance were identified. The findings involved violations of NRC requirements"
Here is what the NRC won't explain. The component design bases inspections comes out of the severe turmoil in the nuclear industry all during the 1990s and the inability of US plants to maintain their licensing bases and component design bases nationwide. Maine Yankee basically was permanently shut down because of this. The outcome of this debacle was to invent a new NRC regime that became known as the component design bases inspection. Only god knows why their component design bases wasn't first firmly established and enforced before all the US plants first become operational. Once we got to the first CDBI report at around the 2006 and the resultant 11 violations such as Palisades, wasn't it the duty of Palisades to clear out from the documentation any further violation. Why doesn't Palisades think is is their duty never to have a federal violation or violations of their own procedures approved by the NRC? Why is it in the nuclear industry's philosophy, that NRC violations are the price of an operating plant and profits.
(December 2, 2014) CDBI 2014008: 10 violation
This inspection constituted 20 samples as defined in Inspection Procedure 71111.21-05.
(September 12, 2011) CDBI 2011009 4 violations
The following 17 components were reviewed:
(January 15, 2009) CDBI 2008009(DRS) 2 violation
This inspection constituted 25 samples as defined in Inspection Procedure 71111.21-05.
(May 19, 2008) CDBI followup 2008008(DRS) O violation (I don't know what this means)
(February 13, 2007) CDBI 2006009(DRS) 11 violations
The following sixteen components were reviewed (16 inspection samples)
Most these violations could have been uncovered decades ago...why did the NRC just discover it in late 2014. Why couldn't the NRC spend enough resources where all of the CDBI violations were cleared off the decks in 2006? Maybe 25 violations the first inspection in 2006, then 2 or 3 for each proceeding inspection. Why wasn't in Palisades pride there was never another violation after 2006.This list just goes to show you the NRC violations and outcome of the ROP doesn't give Entergy the incentive hunt down all possible future NRC violations and fix it before the NRC catches in another decade old violation.
You get it, it is a non cited violation. Palisades don't have to explain publicly how they fixed it.
(November 21, 2014) SECURITY BASELINE INSPECTION REPORT 2014405
One self-revealing finding of very low security significance (i.e., Green as determined by the Physical Protection Significance Determination Process) was identified during this inspection.
Basically their security department is in a failed state...these guys have been getting serious security violations since 2008. Why hasn't the ROP forced them to immediately correct this department permanently without any future violation. All the recent security violation are indications that the ROP doesn't work...it calls more violations to the plant through a bad CAP process and ineffectual corrections.
(November 6, 2014) INTEGRATED INSPECTION REPORT 2014004
We see it may takes years before a URI gets resolved. This is where favor get made by senior executives to Entergy...these guy inappropriately get to chose the amount of violations in a year and how bad it is
(Open) Unresolved Item (URI): Failure to Evaluate the Adverse Effects of the Use of
Non-Seismic Temporary Jumpers.
Come on, their severe weather and wind procedure were insufficient since 1978? They enforced their procedures erratically and in a crazy manner.
Introduction: The inspectors identified a finding of very low safety significance (Green)
and an associated NCV of Technical Specification 5.4.1 when licensee personnel failed
to maintain and implement an adequate procedure covering Acts of Nature. Specifically,
the licensee’s interpretation of abnormal operating procedure (AOP)-38 entry conditions
resulted in a decision not to enter the procedure despite available information indicating
the presence of high wind conditions in the vicinity of the plant.
(October 9, 2014) SECURITY BASELINE INSPECTION REPORT 2014407
However, the inspector documented a licensee-identified violation that was determined to be
of very low security significance (Green) in this report. The NRC is treating this violation as a
Non-Cited Violation (NCV) consistent with Section 2.3.2.a of the Enforcement Policy.
Isn't it better to prevent a violation instead of finding one. You really never know if the NRC poked them in the ribs, forcing them to disclose this.
The site isn't capable of asking the operators the right quality questions at this late stage of the game? Sounds there was something wrong with the training department...the trainer weren't trained and educated enough to know how to write test questions. The training department is in meltdown.
(July 25, 2014) INTEGRATED INSPECTION REPORT 05000255/2014003
Basically the NRC have enough evidence to prove their employees were cheating on operator testing? Again competent training department employees should have easily caught this. it reases question whether the training department is imploding.
Green. The inspectors identified a finding of very low safety significance associated with
10 CFR 55.59, "Requalification," based on a determination that greater than 20 percent of
the biennial requalification written exam questions administered to licensed operators during
weeks three and five of the 2012 examination cycle were flawed.
Competent training department employees know how important is it to control testing material. This isn't a training department failure...it is a failure of integrity. This entails a lot more risk.
Enforcement: Title 10 CFR 55.59, "Requalification," Section 4, "Evaluation," requires,
in part, that the Requalification Program must include written examinations which
determine licensed operators' and senior operators' knowledge of subjects covered in
the Requalification Program and provide a basis for evaluating their knowledge of
abnormal and emergency procedures. However, the regulation does not specify a
requirement for the quality of exam material. Therefore, no violation of regulatory
16
requirements was identified. The licensee entered this issue into the CAP as
CR-PNP-2014-02521. (FlN 05000255/2014003-01, Written NRC Biennial
Examinations Did Not Meet Qualitative Standards)
Green. The inspectors identified a finding of very low safety significance and an associated
non-cited violation of 10 CFR 55.49, “Integrity of Examinations and Tests,” which stated,
“Applicants, licensees, and facility licensees shall not engage in any activity that
compromises the integrity of any application, test, or examination required by this part.”
Again, basically it is a lack of intergrity with the responcibility of filling out fedural paperwork accurately and assuring their employees are healthy.
Pilgrim: June 2 2013: “When it comes to the job of controlling the reactor, unyielding adherence to standards and procedures is essential,” NRC Region I Administrator Bill Dean said at the time. “The NRC fully expects plant personnel to learn from this experience and take steps to ensure there is not a recurrence.”Medical Examinations: Specifically, at various times over a period of almost four years, 10 operators did not meet certain medical requirements (for stamina and/or blood pressure) for performing NRC-licensed operator activities, and the operators continued to perform NRC-licensed activities. Additionally, Entergy did not perform complete medical testing of its licensed operators, in that five of those licensed operators had not been administered stamina tests for more than two years and, therefore, did not complete their NRC-required biennial medical examAccuracy of Information: Specifically, Entergy did not provide information to the NRC that was complete and accurate in all material respects, in that Entergy submitted two NRC licensed operator renewal applications which certified that the applicants met the medical requirements for license renewal when in fact they did not complete the required stamina tests.Notification of Change in Operator or Senior Operator Status: Specifically, Entergy did not notify the NRC within 30 days of discovering a change in medical condition for two licensed operators. In 2010, Pilgrim medical staff became aware of medical conditions that caused two licensed operators to fail to meet the requirements of 10 CFR 55.21 and for which license conditions were required. These apparent violations of operator-licensing regulations, coupled with the procedural errors that contributed to the May 10 scram, had little or no effect on the NRC’s assessment of the overall competency of Entergy staff or the viability of the plant, itself
The licensee did not
notify the NRC of these medical changes until April 11, 2014, a period of greater than
30 days.
Severity Level IV. A Severity Level IV non-cited violation of 10 CFR 50.74, "Notification of
Change in Operator or Senior Operator Status," was identified by the inspectors during a
review of licensed operator medical records. Specifically, Palisades did not notify the NRC
within 30 days of discovering a change in medical condition for a licensed operator.
Subsequently, the licensee submitted the required notification for the operator on
April 11, 2014, and entered the issue into their CAP as CR-PLP-2014-02518, NRC
Description: During a routine plant walkdown in the West Engineered Safeguards Room
on April 17, 2014, the inspectors identified two scaffolds with outdated scaffold tags.
Green. The inspectors identified a finding of very low safety significance and an associated
non-cited violation of 10 CFR 50, Appendix B, Criterion V, “Instructions, Procedures, and
Drawings,” when licensee personnel failed to adequately implement procedure EN-MA-133,
“Control of Scaffolding.” Specifically, multiple examples were identified of scaffolds installed
in the plant for greater than 90 days that had not undergone process applicability
determinations, were not appropriately documented in the scaffold control log, and/or did not
contain proper tags. The licensee documented the issue in their CAP as
CR-PLP-2014-2646, Two Scaffolds Near Safety-Related Equipment Not Being Controlled as
Long-Term, dated April 17, 2014; conducted an extent-of-condition review of the entire
scaffold log and identified additional discrepancies; completed the required process
applicability determinations; and re-inspected scaffolds that had been categorized as
long-term.
Through discussions with the workers, it was identified that the logging of scaffolds,
scaffolding inspections, and process applicability determination review initiations, as
needed, were managed by the Site Scaffold Coordinator during normal plant operations
and by a designated Supplemental Scaffold Coordinator during refueling outages. It was
revealed that during the change between online and outage work activities some
scaffolds were not logged correctly or were thought to have been removed from service
in the plant when they actually remained installed. Also during these discussions, it was
identified by the inspectors that the licensee was not counting days when the plant was
shut down in any calculations of the 90 day time frame for scaffolds installed near SSCs
that were needed when the plant was shut down.
Remember in the CRDM 24 replacement job in 2012 that replaced 12 CDRM housings that report had similar violations of underestimating the planning dose of their worker. Just think, this is just a preliminary finding meaning it will be a year before the NRC will tighten down the screws on Palisades. A lot of times if Palisades presents a deep corrective action to the violation they might downgrade the violation.
Why is the below inspection results eight months late and why isn't the medicine administered when the fever first showed up? Are late inspections and their corrections institutionalized in the ROP.
This un nessi in emanates from an prolonged outage back in Feb 2014. It really starts back in 2012 where they discovered one leaking CRDM, replace 12 of them. Palisades should have done the whole job like 2014 back in the 2012 leak. Palisades presented to the NRC as a radiation dose mitigation strategy replacing a small proportion of the CRDMs this outage, then a larger proportion excluding the heaviest dose center CRDMs ...then they were forced to replace them all. Palisades engineering exspected no CRDM maintenence this outage based on the replacement job last outage and getting a all clear signal with not discovering any cracks in the units. They shokingly discovered new cracking CDRM seals up the ying yang...they even replace the new CRDM housing installed two years ago this Feb 2014.
People really need to think about how poor engineering and botched maintenance drastically increases dangerous complxity...
This is where I make my money. Have we discovered a new vulnerability with aging and obsolete nuclear power plant.
A aging nuclear power plant intermixing with our troubles on the grid and their financial problems, talking about emergent phenomenon. As uncontrollable aging builds up, complexity builds in, resources are stretched thin in the plant and NRC, this increasing blinds everyone in the system and they may not understand they are see less and less, the NRC, economics on the grid works against them or causes a huge head wind...the struggle for survival in limited resources and massive complexity blinds everyone and ends up corrupting the safety culture of the plant, corporation and the NRC. The stresses and contradiction of this system drives people to act not in their best interest and the interest of the greater good. The feedback loops do their thing...the player slide deeper and deeper into survival tunnel vision.
Systems Thinking: Systems Thinking is the art and science of making reliable inferences about behavior by developing an increasingly deep understanding of underlying structure.
System behavior is an emergent phenomenon. How a system behaves cannot be determined by inspection of its parts and structure. This is because parts are tightly coupled, the parts and structure are constantly changing, feedback loops are present, nonlinear relationships exist, behavior paths are history dependent, the system is self-organizing and adaptive, emergent behavior is counterintuitive, time delays exist, the human mind has very limited calculation abilities, etc. Once you realize how complex the behavior dynamics of even a simple system really is, you will never again assume you can look at a system and predict how it will behave.We had the main coolant pump impellers breaking off for decades in the same Feb 2014 outage. They surprisingly found a huge chunk of impeller blade in the reactor. How Palisades treated these conditions told me they were still dangerous and making the wrong choices. Little did I know the NRC would withhold information about the dysfunction of the outage with the rad dose from us all.
Personally I think the NRC officials were trying to publically shape the image of this troubled outage to outsiders. The NRC has a dog in this race... they told us all the Palisades senior management had finally seen the light and a new day was dawning with new blood. By disrupting the accurate reporting of the outage, I think the NRC was really trying to protect the local credibility of the agency.
Palisades should have been heavily monitored in yellow or red finding post outage like I asked them in May...I questioned if they should have ever been allowed to operate again.
Relevant inspection reports:
December 2, 2014: SUBJECT:PALISADES NUCLEAR PLANT, NRC INSPECTION REPORT 05000255/2014010
May 7, 2014: SUBJECT: PALISADES NUCLEAR PLANT INSPECTION REPORT 05000255/2014002
February 12, 2014 SUBJECT: PALISADES NUCLEAR PLANT - NRC INTEGRATED INSPECTION REPORT 05000255/2013005 AND EXERCISE OF ENFORCEMENT DISCRETION
October 17, 2012 SUBJECT:PALISADES NUCLEAR PLANT - NRC SPECIAL INSPECTION TEAM(SIT)REPORT 05000255/2012012So here below I am back in May 2014 in a 2.206, asking the NRC to increase oversight. The NRC withheld from the public the radiation dose violation until this new inspection. It it is like violating the speeding limits, then not getting the speeding ticket for 8 months.
(May 2014) 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 diffusing into safety systems at Palisades.Worst, these guys got a history of being bad actors. The NRC with Arkansas Nuclear One has history of not giving out the speeding ticket for months and years after the violence occurs. The NRC don't immediately ramp up the scrutiny of the plant based on the ROP as a immediate reflection of their misbehavior. If I got caught driving drunk, they would immediately arrest me...they wouldn't allow to drive until the court case and most likely prohibition with driving for a year and required heavy duty alcoholism consulting. I can see them doing this to a good plant...but such a troubled plant like Palisades? Why didn't the NRC presume within weeks the plant was guilty of the repeated dose and HP violations, then jack up the NRC scrutiny as their ROP requires?
Basically the NRC is diluting, dispersing and disrupting disclosing how bad the situation was in Palisades last outage. It is public fraud! How the public perceives this today is, oh, they have issues with the accuracy of dose to Palisades employees. How it should be portrayed, look they had a very difficult outage, they had issues with broken primary coolant pumps impeller, large impellers among other big violation, getting chunks of impeller stuck in the core and serious issues of reporting accurately to the NRC the dose of their employees. Actually, the company is not directly reporting the dose accurately to the employees.
They should be treated as heroes for replacing the CRDMs for the third time? These guys sit way outside how any other PWRs' treats their CDRMs. The greater truth is; the NRC should have explained this in the post outage inspection report how negligently Palisades treated their CRDMs over the life of the plant. How many excess shutdowns they had over them, how much cost this transferred to the ratepayers. Worst yet, how much excess and preventable dose this cost the contractors and the plant employees within the preventable maintenance catastrophe over decades.
That is the real story, not this silowing and selectivity of releasing pleasing information in the aims of protecting a plant like Palisades. All this does is facilitates and excuse dysfunctional behavior corporate wide and at Palisades, all this does is call more dysfunctional to a plant. I don't care if the managers OK'd this behavior, I don't care if the rules said this behavior is fair play, I don't care if the NRC and congress approves this behavior through their law and politicians, I don't care if this is OK'd by the president and he puts his stamp of approval on it all..this is obscenely immoral and not ethical behavior from the whole lot of them. Functionally this demeans the value of human life for the weak and powerless the most. This is a assault to the value of human no matter what your rules or regulations say. I have a huge issue when you think your rules and laws are god...not or never impeachable or because you make it unobservable. I have huges issues when you use government, the laws and regulations as a weapon against the good...use the instrument of government to protect the deceptive liars, thieves, crooks and the whole lot of the deceivers and deceptors.
Right, I talked about the preventable massive complexity of the system that eats up many effectiveness employees in the recent past...make employees and resources in the NRC and Palisades less effective. You just have to be a insider to understand what i am saying. You would have to have a idea of the history of the Palisades Plant and the history of their CRDM problems. All these CDRM shutdowns and start-ups over decades, the startling repeatedly and botched complex CDRM replacements jobs and repeatedly botched replacements. The issues of the extremely high radiation and radiation gradients to troubleshoot and repair, the manpower, training and highly specialized education of all this waste...this collective complexity on a breathtaking large unknowable scale of just the CDRM jobs. It is such a waste of treasure and resources.
Think about how wrong this is. Here is the inspection report right after the Feb 2014 outage. Remember the regulatory small sampling agency I talked about and the extremely small field of view they all allow themselves. This is mindboggling. The NRC is scrambling and disrupting the view with what the outsiders can see. The agency and region III is in big trouble. Then got the PCP problems. I doubt the agency captured the totality of all the violations in this outage. They just had the resources and will to show us a small sampling of what went wrong.
Based on the results of this inspection, two NRC-identified and three self-revealed findings of very low safety significance were identified. Four of the findings involved violations of NRC requirements.
This inspection is suppose to have the defective primary coolant pump problems, the CRDM job and inaccurate dose to the worker issues in it. Why wasn't the inaccurate dose in this...why did it take eight months for the agency to spill the beans.
So here below is a entry from the Feb 2014 outage and May 7 inspection report of the outage. Call me crazy, but this ALARA violation here comes from the Aug 2012 twelve CRDM replacement job and this is in the May 2014 outage report. What the hell? You catch it, Palisades is going to repace the new 2012 CRDM housings again in two years plus all the rest. Why is the old 2012 outage "ALARA (controlling dose) violation" in the current 2014 outage inspection report...why isn't the 2014 "inaccurate dose violation" in its current outage inspection report? The general HP department (radiation control department) is incompetent and inconsistent in a outage realm is like loose fuel pellet flies...the HP violations jump around mysterious sight unseen from one department area into another...from outage to sequential outage. In 2012, it is a failure to understand how hot (radioactive) the CRDM were and they severely underestimated the dose employees would eventually receive. In 2014 Palisades didn't accurately record the doseage of the employees in the same job. Why isn't the punishment culualtive for the same job and it being sequential from one outage to the next?
What is an unresolved item (URI). Whose fault is it? Does it all make sense? Am i crazy? Why is this 2012 CDRM violation in May CDRM 2014 just after the Feb 2014 outage. Why isn't the Feb 2014 dose violation in the May 2014 inspection report.
This inspection was completed on Dec 31 2013, probably didn't get on the NRC's internet site until March. The outage began on March 15 and was complete on March 16, maybe didn't see the outage inspection report till June 2014. Certainly Entergy knew about this entry being in this inspection by Dec 31 2014. They knew the NRC was sitting this up as a warning to not botch the upcoming outage...Get HP and employee dosage right. The dose estimation was only off by 900%.
But how in god's name did this get here? It is going to turn into a violation on the May 20014 inspection report outlining poor Palisades activities in the March 2014 outage. A 2012 CRDM outage violation is going to show up after the 2014 CRDM outage on NRC's document months after the 2014 outage. Now we know why the 2012 violation showed up showed up on the NRC's internet site sometime in June 2014. The 2014 March outage CDRM dose violation demanding more NRC oversight shows up on Dec 2, then won't get deposition into more NRC oversight until probably June 2015. Does this make sense. I get it, this the process and the NRC staff is just following the rules. The rules are a unimpeachable god behind the curtain!
Why is it two years late? Now we know, Palisades refused to turn in their dosage and the NRC failed to demand it right after the Aug 2012 outage. Why did the NRC wait this long...why didn't the agency demand it. See, there is no explanation why it is so late? I bet you they just forget about it. This only happens to a overwhelmed NRC and Palisades staff. See, they wouldn't let us see under the covers of both their dysfunctions, see if being overwhelmed is affecting safety at the plant See if the NRC's staff being overwhelmed if it affecting the oversight of the plant. Man, there is just a bunch of self interested secrets, secretively withholding information to engineering a public image for elite self interest.
Personally I think Entergy withheld this damning information to NRC to force the agency to delay releasing the violation...to defuse accountability of wrongdoing. They are engineering a false public perception of the plant's behavior. If the NRC was a "hard ass" about dose violation in the vicinity of the Aug 20012, we never would have had a dose violation in the March 2014 CDRM outage...the agency now wouldn't be contemplating in Mid Dec 2014 jacking up Palisades Oversight around June 2014. Do you people realize how crazy this sounds. A disruption in the nuclear industry will have a dire national outcome!!!
It is a sorry state of human affairs in our world today...but it critical for somebody to play the hard ass role.
Will this Dec 2, 2014 violation from the March 2014 CRDM outage gain quicker Palisades accountability and it required correction than the 2012 CDRM outage violations???
Here is a 2013 inspection report and the results of the inspection comes out in Feb 2014. It is just before the March 2014 outage and its resultant HP dose violation. Why is a April 2012 HP violation in a 2013 inspection report and it gets disclosed in a Feb 2014 inspection report? This show absolute contempt with the staff on understanding the radiation control rules and obeying them. You get it, I was just talking about the second 2012 outage above? This is a completely different outage...this is first one of 2012. What if the agency was a "hard ass" here on the first 2012 outage and made Palisades senior executives knees tremble with the fear of the agency's voice? Would the souls of the next two outages be unblemished and perfect like the rest of us?
This is how the NRC tems it: "Inadequate Control of Entry Into High Radiation Areas. Right, the leaking CRDM of Aug 2012 outage ending with the replacement 12 CDRM is quickly approaching. We are heading for serious radiation control violation in the next two identical two outages. It is all leading to increase plant scrutiny probably beginning in 2015. You see how closely related this violation is to the next two outage violations before the 12 CRDM outage.
This is Palisades in normal refueling outage in April 2012 , heading for a startup and then a forced outage in Aug 2012 to repair 12 CRDM. If the NRC had their head on straight in the April outage, properly seized up the true conditions of the HP department...used the full powers of the agency to demand get a immediate change in behavior of the Palisades...then the dose control violation in the next two outage CDRM violations and the increased scrutiny in some time in 2015 would never have occurred. You see how right behavior heads off future complexity. What comes out of this whole debacle is the politicians, the president and congress have turned the NRC into nothing but paperwork pushers. The ends of the agency is to complete the paperwork according to their rules, not use the agency powers and resources to do good.
This speaks of the importance of the agency accurately sizing up the true condition of a nuclear plant department, get it immediately down in the record....then do what it takes using the full powers of the agency to quickly change the behavior of a bad actor. Shit man, it is only off by 200%? In the near future, it will be off by 900%.
So back to the Feb 2014 NRC inspection report, the NRC is detaining radiation dose control problems in the first April 2012 normal amount a lot of other problems. The NRC is a small sampling regulator, they only see a small proportion of the current problems because the are so resourced limited. We get to finally see reason why the the second 2012 shutdown leaking CRDM..the 12 CRDM replacement radiation control problem popped up into the May 2014. Where the early Feb 2014 radiation control accurate dose violations showed up nine month late.
Collectively with the NRC in their ROP, their inspection reporting cycles and risk significance, they are dissociating cause and effect.
I just realized, I don't yet know why they delayed the dose violation from the 2012 CRDM 24 outage....that was entered into the Feb 2014 violation
https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML13134A329
May 14, 2013: SUBJECT: PALISADES NUCLEAR PLANT INTEGRATED INSPECTION REPORT 05000255/2013002
Findings
Introduction: The inspectors identified a finding of very low safety significance (Green) and associated NCV of TS 5.4.1 for the failure to perform derived air concentration (DAC)-Hour tracking for airborne transuranic radioactivity as required by station
Procedure EN-RP-131, “Air Sampling” resulting in untimely internal dose assessments for selected plant workers.
Description: The inspectors identified an issue of concern in that the licensee did not perform effective DAC-Hour tracking and resultant dose assessments for airborne transuranic radioactivity for workers that were working in the reactor cavity and steam generator nozzle areas.
The NRC has established annual limit(s) on intake (ALI) for worker(s) that is the derived limit for the amount of radioactive material taken into the body of an adult worker by inhalation or ingestion in a year. The DAC means the concentration of a given radionuclide in air which, if breathed by the reference man for a working year of 2,000 hours under conditions of light work, results in an intake of one ALI. The term derived air concentration-hour (DAC-hour) is the product of the concentration of radioactive material in air and the time of exposure to that radionuclide(s), in hours. A licensee may take 2,000 DAC-hours to represent one ALI. The effective tracking of workers DAC-hour(s) exposures is a calculation method that is used to estimate workers’ committed effective dose equivalent (internal dose).
(May 2014 inspection report Pg 38) Failure to Maintain Radiation Exposure ALARA During Control Rod Drive Mechanism (CRDM) 24 Repairs
Introduction: A finding of very low safety significance (Green) was self-revealed due to unplanned and unintended occupational collective radiation dose that was received as a result of deficiencies in the licensee’s Radiological Work Planning and Work Execution Program. Specifically, the licensee failed to properly incorporate ALARA strategies and insights while planning and executing work activities on CRDM 24 during an August 2012 maintenance outage. This issue was originally identified as Unresolved
Item (URI) 05000255/2013005-04, “Evaluation of Dose Received by Workers Repairing CRDM 24.”
Description: During an August 2012 maintenance outage, numerous work tasks were performed, including repairs to the CRDM 24 housing. The initial dose estimate for this RWP was 2.950 Rem. The actual dose incurred was 26.563 Rem. The licensee provided data that was incomplete in several areas. However, the inspectors concluded 39 that a nominal 8.5 person-Rem of exposure was beyond the licensee’s ability to foresee and correct and was attributable to emergent work. Specifically, the dose attributed to the necessity to inspect additional CRDM housings as part of the licensee’s extent of condition review was discounted from regulatory consideration by the inspectors. The inspectors also excepted from regulatory consideration the dose attributable to implementation of ALARA dose reduction strategies, such as the installation of additional shielding in the work area. However, the inspectors concluded that several work planning and work execution issues were within the licensee’s ability to foresee and correct, and therefore, should have been prevented. Specific examples included ultrasonic testing exams that were re-performed due to insufficient or inadequate initial exams, poor coordination of shielding installation and removal that necessitated field re-work, and inadequate mock-up testing that resulted in in-field work activities that contributed to additional dose to the workers. The inspectors concluded that the work planning and execution issues that were within the licensee’s ability to foresee and correct, and therefore that should have been prevented, resulted in collective doses greater than 5 Rem and greater than 150 percent of the initial dose estimate.
This ALARA thing below is misnormer.I think they gave the HP department and their contractors a impossible job in such a short notice. The root cause is not a failure for the HP department to control dose...it is a failure of Palisades who created the dose and the initial poor design of the reactor head and the CRDMs to last a lifetime without leaking. It was a mistake to keep replacing these defective CRDM with a poorly designed new CRDMs and housing. This is a mixture of poor primary system chemistry control and fuel rods leaking leading to preventable elevated radiation levels and contamination level. The clumsy HP department and contractor just contributed to theThe licensee entered this issue into their CAP as CR-PLP-2012-05812, UT Exams of the Additional CRD Stalk Housings Has Exceeded the Dose Estimate for the RWP.
Corrective actions were implemented to address the outage planning and work execution issues.
(2012)Failure to Maintain Radiation Exposure ALARA During Control Rod Drive Mechanism (CRDM) 24 Repair.
This inspection was completed on Dec 31 2013, probably didn't get on the NRC's internet site until March. The outage began on March 15 and was complete on March 16, maybe didn't see the outage inspection report till June 2014. Certainly Entergy knew about this entry being in this inspection by Dec 31 2014. They knew the NRC was sitting this up as a warning to not botch the upcoming outage...Get HP and employee dosage right. The dose estimation was only off by 900%.
But how in god's name did this get here? It is going to turn into a violation on the May 20014 inspection report outlining poor Palisades activities in the March 2014 outage. A 2012 CRDM outage violation is going to show up after the 2014 CRDM outage on NRC's document months after the 2014 outage. Now we know why the 2012 violation showed up showed up on the NRC's internet site sometime in June 2014. The 2014 March outage CDRM dose violation demanding more NRC oversight shows up on Dec 2, then won't get deposition into more NRC oversight until probably June 2015. Does this make sense. I get it, this the process and the NRC staff is just following the rules. The rules are a unimpeachable god behind the curtain!
Why is it two years late? Now we know, Palisades refused to turn in their dosage and the NRC failed to demand it right after the Aug 2012 outage. Why did the NRC wait this long...why didn't the agency demand it. See, there is no explanation why it is so late? I bet you they just forget about it. This only happens to a overwhelmed NRC and Palisades staff. See, they wouldn't let us see under the covers of both their dysfunctions, see if being overwhelmed is affecting safety at the plant See if the NRC's staff being overwhelmed if it affecting the oversight of the plant. Man, there is just a bunch of self interested secrets, secretively withholding information to engineering a public image for elite self interest.
Personally I think Entergy withheld this damning information to NRC to force the agency to delay releasing the violation...to defuse accountability of wrongdoing. They are engineering a false public perception of the plant's behavior. If the NRC was a "hard ass" about dose violation in the vicinity of the Aug 20012, we never would have had a dose violation in the March 2014 CDRM outage...the agency now wouldn't be contemplating in Mid Dec 2014 jacking up Palisades Oversight around June 2014. Do you people realize how crazy this sounds. A disruption in the nuclear industry will have a dire national outcome!!!
It is a sorry state of human affairs in our world today...but it critical for somebody to play the hard ass role.
February 12, 2014: EA-13-263 PALISADES NUCLEAR PLANT - NRC INTEGRATED INSPECTION REPORT
February 12, 2014 EA-13-263 SUBJECT: PALISADES NUCLEAR PLANT - NRC INTEGRATED INSPECTION REPORT 05000255/2013005 AND EXERCISE OF ENFORCEMENT DISCRETION Findings Introduction: The inspectors identified a URI concerning the collective dose received by workers repairing the CRD-24 housing during the August 2012 forced outage.Description: During the August 2012 forced outage, numerous work tasks were performed, including repairs of the CRD-24 housing. The initial dose estimate for this work as reflected on the Radiation Work Permit (RWP) was 2.950 Rem. The actual dose expended was 26.563 Rem. The data provided by the licensee at the time of the onsite inspection was not sufficient for the inspectors to complete their regulatory review of the collective dose received during this work activity. The licensee provided additional data to the NRC on January 7, 2014, that will be used to determine whether the dose received was within the licensee’s ability to control.24 This issue is an URI pending completion of the inspectors’ evaluation of the additional information provided by the licensee (URI 05000255/2013005-04, Evaluation of Dose Received by Workers Repairing Control Rod Drive-24).This isn't 5 violations in the May outage...it is really six violation and the missing violation is so serious it is going increase the oversight of the plant. It is going to be beyond a year before the increased NRC scrutiny kicks in and they do increased inspection reports. More harmless and grossly delayed paperwork spitballs shot at Palisades by the powerless NRC in the hopes of changing the hearts of the senior Palisades officials.
Will this Dec 2, 2014 violation from the March 2014 CRDM outage gain quicker Palisades accountability and it required correction than the 2012 CDRM outage violations???
Based on the results of this inspection, two NRC-identified and three self-revealed findings of very low safety significance were identified. Four of the findings involved violations of NRC requirements.Man, they just keep racking up the points on violations.
February 12, 2014 SUBJECT: PALISADES NUCLEAR PLANT - NRC INTEGRATED INSPECTION REPORT 05000255/2013005 AND EXERCISE OF ENFORCEMENT DISCRETION
Based on the results of this inspection, three NRC-identified findings of very low safety significance were identified.
Here is a 2013 inspection report and the results of the inspection comes out in Feb 2014. It is just before the March 2014 outage and its resultant HP dose violation. Why is a April 2012 HP violation in a 2013 inspection report and it gets disclosed in a Feb 2014 inspection report? This show absolute contempt with the staff on understanding the radiation control rules and obeying them. You get it, I was just talking about the second 2012 outage above? This is a completely different outage...this is first one of 2012. What if the agency was a "hard ass" here on the first 2012 outage and made Palisades senior executives knees tremble with the fear of the agency's voice? Would the souls of the next two outages be unblemished and perfect like the rest of us?
Inadequate Control of Entry Into High Radiation Areas (HRAs)
(Feb 2014)Green. The inspectors identified a finding of very low safety significance and two associated NCVs of TS 5.7.1 and one associated NCV of TS 5.7.2 when on three separate occasions, three separate workers unknowingly entered areas with greater than expected dose rates. Specifically, on April 10, 2012, the radiation protection (RP) staff inappropriately authorized plant personnel to enter a locked high radiation area in the Auxiliary Building Pipe chase (ABP) 602' elevation that had not been appropriately radiologically characterized prior to the entry; and on April 25, 2012, and again on April 27, 2012, workers inside the containment 607' elevation staging equipment at the ‘B’ steam generator (S/G) manway inappropriately traversed high radiation areas with elevated dose rates near the ‘A’ S/G cubicle. On both occasions, workers deviated slightly from the briefed travel paths. The licensee entered this issue into their CAP as CR-PLP-2012-03229 and CR-PLP-2012-03313, and as part of their corrective actions, shared lessons learned from this issue with the RP staff to address survey adequacy and for enhanced communications with workers during pre-job briefings.
This is how the NRC tems it: "Inadequate Control of Entry Into High Radiation Areas. Right, the leaking CRDM of Aug 2012 outage ending with the replacement 12 CDRM is quickly approaching. We are heading for serious radiation control violation in the next two identical two outages. It is all leading to increase plant scrutiny probably beginning in 2015. You see how closely related this violation is to the next two outage violations before the 12 CRDM outage.
This is Palisades in normal refueling outage in April 2012 , heading for a startup and then a forced outage in Aug 2012 to repair 12 CRDM. If the NRC had their head on straight in the April outage, properly seized up the true conditions of the HP department...used the full powers of the agency to demand get a immediate change in behavior of the Palisades...then the dose control violation in the next two outage CDRM violations and the increased scrutiny in some time in 2015 would never have occurred. You see how right behavior heads off future complexity. What comes out of this whole debacle is the politicians, the president and congress have turned the NRC into nothing but paperwork pushers. The ends of the agency is to complete the paperwork according to their rules, not use the agency powers and resources to do good.
This speaks of the importance of the agency accurately sizing up the true condition of a nuclear plant department, get it immediately down in the record....then do what it takes using the full powers of the agency to quickly change the behavior of a bad actor. Shit man, it is only off by 200%? In the near future, it will be off by 900%.
Specifically, the worker received an electronic dosimeter (ED) dose rate alarm of 692 mrem/hr when he entered an area that had actual dose rates of up to 1300 mrem/hr.This is termed by the NRC as having a insignificant safety consequence...but the dysfunction of Palisades senior management and their HP department is going to carry over into two sequential CRDM outages and into increase NRC scrutiny of Palisades because of poor radiation control performance somewhere in 2015. The risk perspectives punishment or incentives that looks in the rear view mirror doesn't see the future organizational disorder and its true risk to the plant and public. This artificial minimization of risk needing perfect proof or evidence of future risk and disorder that is unobtainable, doesn't incentivized the agency to the true risk (the future violations in the next two outages. The NRC doesn't understand the efficacy of immediately recognizing the true organization disorder and clear out the chaos immediately based on the true risk. The ROP and risk perspectives dilutes the understanding of real risk, this causes the agency to be adverse to positively interacting with a Plant at the earliest opportunity with emergent disorder equivalent to the necessity of the future real risk. Really the proper operation of a good plant is contingent on minimization of complexity and all the facts of the systems and organization to have the fact immediately on the table for all to sees and act on.
The finding was not subject to traditional enforcement since the incident did not have a significant safety consequence, did not impact the NRC’s ability to perform its regulatory function, and was not willful.In other words,once the NRC sees and understand true disorder it is already too late. The complacency of the agency had already injected too much destructive disorder and complexity into the plant. Eventually the NRC is going to have to come in with a much heavier hammer that is necessary to correct the wrong thinking of the system. If the NRC still doesn't get it, the disorder and complexity will create a public event or accident necessitating a much larger hammer. If the NRC still doesn't understand real risk and the conditions of the plant's staff...the disorder and complexity will emerge from the plant as a accident or media credibility issue causing a permanent plant shutdown.
So back to the Feb 2014 NRC inspection report, the NRC is detaining radiation dose control problems in the first April 2012 normal amount a lot of other problems. The NRC is a small sampling regulator, they only see a small proportion of the current problems because the are so resourced limited. We get to finally see reason why the the second 2012 shutdown leaking CRDM..the 12 CRDM replacement radiation control problem popped up into the May 2014. Where the early Feb 2014 radiation control accurate dose violations showed up nine month late.
Collectively with the NRC in their ROP, their inspection reporting cycles and risk significance, they are dissociating cause and effect.
Evaluation of HRA Controls on the Refuel FloorIntroduction: The inspectors identified an Unresolved Item (URI) concerning the control of a HRA specified in TS 5.7.1 for refuel floor activities on April 18, 2012. Description: On April 18, 2012, while work was being performed on the refuel floor that changed general area dose rates (removal of the Upper Guide Structure), a worker entered an area within a HRA on the refuel floor in which the worker was unaware of the dose rates present. On January 10, 2014, the RP manager provided the NRC with additional information regarding HRA controls that were in place during this entry.The issue is an URI pending completion of an evaluation of the additional information provided by the licensee (URI 05000255/2013005-03, Evaluation of HRA Controls on the Refuel Floor).
I just realized, I don't yet know why they delayed the dose violation from the 2012 CRDM 24 outage....that was entered into the Feb 2014 violation
https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML13134A329
May 14, 2013: SUBJECT: PALISADES NUCLEAR PLANT INTEGRATED INSPECTION REPORT 05000255/2013002
Findings
Introduction: The inspectors identified a finding of very low safety significance (Green) and associated NCV of TS 5.4.1 for the failure to perform derived air concentration (DAC)-Hour tracking for airborne transuranic radioactivity as required by station
Procedure EN-RP-131, “Air Sampling” resulting in untimely internal dose assessments for selected plant workers.
Description: The inspectors identified an issue of concern in that the licensee did not perform effective DAC-Hour tracking and resultant dose assessments for airborne transuranic radioactivity for workers that were working in the reactor cavity and steam generator nozzle areas.
The NRC has established annual limit(s) on intake (ALI) for worker(s) that is the derived limit for the amount of radioactive material taken into the body of an adult worker by inhalation or ingestion in a year. The DAC means the concentration of a given radionuclide in air which, if breathed by the reference man for a working year of 2,000 hours under conditions of light work, results in an intake of one ALI. The term derived air concentration-hour (DAC-hour) is the product of the concentration of radioactive material in air and the time of exposure to that radionuclide(s), in hours. A licensee may take 2,000 DAC-hours to represent one ALI. The effective tracking of workers DAC-hour(s) exposures is a calculation method that is used to estimate workers’ committed effective dose equivalent (internal dose).
On April 16, 2012, the reactor cavity was posted as “Alpha
Level 3” and “airborne radioactivity area.” This designation indicated that
elevated concentrations of alpha emitting radionuclides were present in the
reactor cavity. It also alerted the radiation protection staff of the presence
of increased radiological hazards in the area, and that additional controls
were required to effectively monitor and control workers’ internal radiation
exposures. One of the additional requirements was to perform DAC-Hour tracking
utilizing Procedure EN-RP-131, “Air Sampling,” Attachment 9.9, when the alpha
air sample analysis results exceed 0.15 DAC. On April 16, 2012, the reactor
cavity was posted as “Alpha Level 3” and “airborne radioactivity area.” This
designation indicated that elevated concentrations of alpha emitting
radionuclides were present in the reactor cavity. It also alerted the radiation
protection staff of the presence of increased radiological hazards in the area,
and that additional controls were required to effectively monitor and control
workers’ internal radiation exposures. One of the additional requirements was
to perform DAC-Hour tracking utilizing Procedure EN-RP-131, “Air Sampling,”
Attachment 9.9, when the alpha air sample analysis results exceed 0.15 DAC. The
actual air sample results indicated 0.21 DAC from alpha radionuclides...
When questioned by the inspectors, the licensee had difficulty supplying the requested Procedure EN-RP-131, “Air Sampling,” Attachment 9.9, DAC-Hour tracking form for some of the workers observed in the reactor cavity. The licensee indicated that there was a backlog of air samples that required more detailed radio-chemical analysis. This issue had been documented in the licensee’s CAP as CR-PLP-2012-02683. The corrective action document stated “Radiation protection airborne radioactivity air samples are not being analyzed in a timely manner.” However, effective corrective actions had not been implemented at the time of the initial NRC inspection. Delays in analyzing radioactive air sampling media can impact RP job coverage and worker’s dose assessment. The inspectors expanded the scope of review to include other “Alpha level 3” designated areas, including installation of the steam generator nozzle dams. Some workers installing the steam generator nozzle dams had their respiratory protection equipment fail while in-service. The licensee could not provide the inspectors the necessary DAC-Hour tracking information when requested. Procedure EN-RP-131, “Air Sampling,” required additional actions to be taken if the DAC Hour tracking form identified a worker that exceeded 4 DAC-Hours (10 millirem) in a 7-day period. This activity could not be completed for the workers performing steam generator nozzle dam installation and other work groups. This was an issue with work execution and
30 Enclosure
procedure adherence and not radiological work planning. Although alpha airborne monitoring and individual dose assessments were not performed in accordance with station procedures, there was sufficient oversight of the Airborne Radiation Program in place to identify significant changes in alpha radiation hazards at the plant. Specifically, the licensee was performing gross alpha monitoring of selected work activities.
Although the issue was initially documented in the licensee’s CAP, the inspectors identified previously unknown weaknesses in the licensee’s internal dose assessment process and in the corrective actions necessary to restore compliance. Consequently, the licensee reassessed their program for monitoring and controlling personnel in elevated alpha airborne areas of the plant. Additionally, the licensee performed internal dose assessments for workers that had entered and worked in all alpha airborne areas during the outage. This was a significant effort, in that, the licensee needed to evaluate each individual radiologically controlled area entry to determine which personnel had entered alpha airborne areas; determine the airborne isotopic mixes and isotopic concentrations; determine alpha airborne area exposure times; and then perform individual dose assessments. The doses were assessed based on station documentation of access to the airborne radioactivity areas through the radiological work control process and the monitoring and evaluation of airborne radioactivity samples collected during the outage. When uncertainties were identified, the licensee used conservative assumptions in order to determine bounding conditions. There were 59 workers that were assigned internal radiation exposure as a result of this issue with the highest individual exposure estimate of 56 mrem.
*Although the issue was initially documented in the licensee’s CAP, the inspectors identified previously unknown weaknesses in the licensee’s internal dose assessment process and in the corrective actions necessary to restore compliance.
Got to find them two guys forgotten alarming dosimeters????
Alleged Palisades violation could bring new scrutiny
N-plant accused of unsatisfactory worker protectionsPosted: Wednesday, December 10, 2014 5:00 am | Updated: 9:04 am, Wed Dec 10, 2014.
Alleged Palisades violation could bring new scrutiny
By ANDREW LERSTEN - HP Staff Writer |
COVERT - Federal nuclear regulators say they found a safety violation of "low to moderate safety significance" at the Palisades nuclear power plant earlier this year.
The NRC issued a report last week on its preliminary "white finding" at the plant, related to methods used to calculate exposure to radiation by workers who were replacing control rod drive housings between January and March.
But if it stands, the NRC would downgrade the safety status of the plant and boost its regulatory oversight, NRC spokeswoman Viktoria Mitlyng said.
Plant spokeswoman Lindsay Rose said Tuesday the company will respond to the finding by Friday.
"We took multiple actions during the course of the work to ensure that radiation exposure would be kept as low as possible and that workers' exposure would be accurately measured and assessed," she said.
The alleged violation related to methods used to track radiation exposure, with the use of dosimeters, and specifically whether they were properly placed on the workers to most accurately determine the radiation doses.
In its report, the NRC included a series of photos of the workers, purporting to show how protective vests were worn. However, there were alleged gaps in the protection provided by the vests due to how they were worn or positioned.
The NRC concluded that it appears no workers received higher-than-allowed radiation doses, but the problems had the potential to have low to moderate safety significance.
The color-coded violation system used by the NRC includes green, white, yellow and red, with green having the lowest safety significance.
The plant is in the highest of four safety status categories used by the NRC, but the white finding would bring the plant down to the second-highest category if it stands, Mitlyng said. The NRC did downgrade the plant that category a few years ago, but it was a temporary status until it returned to the top category.
May 5, 2014
Palisades 2.206 PCP Broken Impeller: Emergency Request to Stay Shutdown
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 diffusing 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!
