Thursday, December 11, 2014

(works in progress)

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-2014-04683
How 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 exam
Accuracy 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 ThinkingSystems 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 05000255/2012012
So 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.    
(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. 
The 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.
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 the 
(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 Floor
Introduction: 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 WriterThe Herald-Palladium |
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!

Wednesday, December 10, 2014

Russian Nuclear Safety Proposal Put Focus on U.S. Reactors

Generally people don't understand that the US response to Fukushima has hidden attributes. A Fukushima style accident is very rare. For a lot of the DBA accident, these utilities have a lot of for show safety systems. Safety systems with the consistency of paper mache. Basically the systems have never been tested or ever operated in real world condition and certainly not vetted for the stress of an accident. The flex components fit into this category but there are some value for these components. So risk perspectives places a not justified value on the increase of safety with the flex components and the installed plant paper mache safety systems. Basically these fake systems "possibly used" extremely infrequency justified more violations of the rules and with broken and degraded components up at power. In other words, the increments of safety increase these systems cause in extremely infrequent accidents or never use is vastly disproportionate to the increase of risk allowed by operation with bum components and people not following the rules...meaning the risk of tolerating operating bum systems vastly outweighs the increase of safety in grossly infrequent accidents. This directly translates into unjustified capacity factor and fraudulent profits. These fake systems make tons of money and it is possible the only justification for these "never used" components and systems is to bolster capacity factor.
     
So say blades are flinging off main coolant pump impellers for decades, they put this in a computer program that comes up with risk. If they include in the program the flex system and the paper mache safety systems, then the program will put the defective impellers into the safe category. If these questionable safety systems are removed, then it would have come up us unsafe. As I said, risk perspective that nobody understand in conjunction with paper mache safety system, this allows the industry to operate with more degraded and broken safety system.

This is altruism abuse....using a veneer or the thin shell of doing good or altruism to hide enormous corruptions or increasing the chance of hurting people for selfish interes
Russian Nuclear Safety Proposal Put Focus on U.S. Reactors
 December 10, 2014

Russia scaled back opposition to European proposals to improve the safety of nuclear power, leaving the U.S. as the main dissenter to new rules intended to avoid a repeat of Japan’s 2011 meltdown in Fukushima.

Russia changed its stance at a Dec. 4 meeting of nuclear diplomats, setting out the Moscow government’s view of new rules to limit radioactive contamination in the event of a nuclear accident, according to a copy of the 13-page presentation seen by Bloomberg. The move raised the chances of a deal to strengthen the Convention on Nuclear Safety, according to three Western diplomats present at the meeting, who asked not to be identified because the talks were private.

The European Union is trying to find a path to tighter safety rules for the world’s aging nuclear reactors with its relationship with Russia overshadowed by the conflict in Ukraine.
Yet it’s the U.S., the world’s biggest nuclear-power generator, that is proving the biggest obstacle, the diplomats said, as company investments in reactor safety lag those of European peers.
U.S. resistance to the European safety proposals is a“serious concern,” Senators Barbara Boxer and Edward Markey said in a Dec. 1 letter to Nuclear Regulatory Commission chairman Allison Macfarlane. The Democrats urged U.S. diplomats to work with “international partners” to amend safety flaws exposed by the 2011 Fukushima Dai-Ichi meltdowns.
Two Proposals
Russia abandoned its opposition to tightening international rules on reactor safety the day after reports of a nuclear accident in Ukraine. The reported mishap -- which ultimately proved to be false -- roiled markets and sent Ukrainian bond yields to a record high. The 1986 meltdown of a Soviet-built reactor in Chernobyl, about 80 miles north of the capital Kiev, weighed on Ukraine’s budget for decades and resulted in a 2,600 square kilometer (1,000 square miles) exclusion zone.

The European proposal would compel nuclear operators to both prevent accidents and, should they occur, mitigate the effects of radioactive contamination. Most controversially, the treaty change would also force potentially costly upgrades at existing plants.

More than half of the world’s 438 reactors were built at least 30 years ago and are nearing the age when they’ll need special attention, according to International Atomic Energy Agency statistics.

The Russian plan would stop short of requiring old nuclear plants to retrofit reactors with costly infrastructure. Such measures would threaten their economic viability, according to Russia’s envoy, Yury Ermakov, who delivered the presentation.
U.S. Opposition
“Absolute achievement of this objective is economically unreal at the vast majority of existing nuclear power plants,”reads the document. Safety improvements mitigating radiation releases should “be oriented towards these objectives” without over burdening companies, it said.

Russian diplomats accredited to the International Atomic Energy Agency, host to last week’s meeting, declined to comment.

U.S. diplomats say their opposition to the European initiative is driven by concern that an attempt to amend the convention could weaken the rules, because some governments would be slow to ratify changes.

“It’s a difficult, long time-consuming process and it may actually damage global nuclear safety,” the NRC’s MacFarlane said in Dec. 3 Senate testimony. “We are heavily involved in working with the State Department who has the lead on the negotiations.”
The U.S. wants signatories to reaffirm treaty commitments that oblige them to undergo rigorous peer reviews from international nuclear regulators, said a U.S. official who asked not to be identified following diplomatic rules.
French Measures
European diplomats have rejected U.S. charges that their proposed amendment risks undermining safety by creating uneven international regulations. Uneven rules were already created in July when the EU passed legislation forcing nuclear operators to retrofit facilities.
“People in the U.S. don’t realize that in many ways our nuclear safety standards lag behind those in Europe,” former NRC commissioner Victor Gilinsky said in a written reply to questions. “The German and French containment structures are generally more formidable than ours and those reactors generally have more protection systems.”

In France, engineers are designing reinforced bunkers for back-up power and installing emergency cooling systems to avoid a meltdown. Europe’s biggest atomic-energy producer is also reinforcing the concrete bases of its oldest reactors and creating elite teams of emergency responders.
Regulators worldwide have tried to boost safety standards in response to the Fukushima meltdown, which forced 160,000 people to flee radioactive contamination after a tsunami flooded safety back-up systems.

The NRC is still working out the parameters on how it values human lives at risk from a nuclear accident, spokesman Scott Burnell said. The value helps determine how much nuclear-plant operators need to spend on backfitting reactors with new safety gear. The NRC was criticized Dec. 3 by Boxer, chairman of the Senate’s Environment and Public Works committee, for being slow to ensure plant safety improvements.

“Some reactor operators are still not in compliance with the safety requirements that were in place before the Fukushima disaster,” Boxer said. “This is unacceptable.”

To contact the reporter on this story: Jonathan Tirone in Vienna at jtirone@bloomberg.net

To contact the editors responsible for this story: Alan Crawford at acrawford6@bloomberg.net Ben Sills, Chad Thomas

Your Life Is Worth $6 Million Less in a Nuclear Meltdown


By Jonathan Tirone December 10, 2014

If you wrap your new car around a tree beside the interstate, the U.S. government values your life at $9 million. If you’re at risk from a nuclear accident, you’re priced at just $3 million.
Those are the figures the U.S. Transportation Department and the Nuclear Regulatory Commission use when considering safety upgrades for highways or nuclear power plants. Their methods compare the cost of improvements with the number of lives potentially saved. The gap between the value they give to each life shows the scale of the task facing officials trying to broker a deal to improve nuclear safety around the world.

The NRC has been reviewing its statistical model since August 2012 as the European Union heaps pressure on the U.S. to agree to tighter regulations on reactor safety. The theoretical value of a human life is a key part of the U.S. rulebook, which effectively caps how much power companies can be forced to spend on safety upgrades.


“Using this low value has a significant effect on nuclear plant license renewals and new reactor approvals,” said Ed Lyman, a Washington-based physicist at the Union of Concerned Scientists. “Nuclear plants are not required to add safety systems that the NRC deems too expensive for the value of the lives they could save.”

The U.S. was left as the main dissenter in negotiations over tighter international rules on nuclear safety this month as Russia scaled back its opposition to plans intended to avoid a repeat of Japan’s 2011 nuclear-plant meltdown at Fukishima.

The NRC hasn’t determined whether to revise the figure, spokesman Scott Burnell said in an e-mailed reply to questions.

Cost-Benefit Analysis

The NRC’s lower value on American lives means that regulators have struggled to force nuclear operators to invest in safety infrastructure at plants under license. The U.S. is against a proposed European amendment to the Convention on Nuclear Safety forcing regulators to show how they’re improving safety and mitigating against accidents.

“The nuclear industry complained about the number of changes they had to make,” former NRC commissioner Victor Gilinsky said in an e-mail response to questions. Rules now require “a cost-benefit analysis to justify any NRC action,” he said.

A higher value placed on human lives, like the one the Department of Transportation uses, could change NRC risk assessments, which consider the consequences of a potential accident along with their probabilities, said Lyman. A Department of Transportation public-information official declined to comment on the disparity.


Industry Response

“The NRC does focus on the quantitative factors in reaching many of these decisions,” Chairman Allison Macfarlane said in Dec. 3 Senate testimony. “Some of the quantitative factors that are considered are themselves not necessarily fully quantitative like the price of -- the cost of a human life.”

The U.S. Nuclear Energy Institute, the Washington-based advocacy group promoting more atomic power, has criticized regulators for imposing onerous requirements.

“Resources are being spent complying with requirements that have little or no safety benefit,” said NEI senior vice president Anthony Pietrangelo at the same Dec. 3 hearing. “If the NRC more accurately estimated the cost of its regulatory requirements it would find that many of its requirements do not pass a simple cost-benefit test.”


While U.S. nuclear operators have set up regional emergency-response centers and invested in safety equipment, their French counterparts are spending four times more, according to industry estimates. 

Tuesday, December 09, 2014

Are your “nads” safe: Seeing the Big Picture with the NRC and Palisades in One Design Inspection Report?


I am a mind reader? This just came out on the internet site Dec 17. See you there.
PUBLIC MEETING ANNOUNCEMENT
Title: Meeting to Discuss Effectiveness of CDBI Inspections
Date(s) and Time(s): January 13, 2015, 12:30 PM to 03:30 PM
Location: NRC Three White Flint North, HQ-3WFN-9A32
11601 Landsdown Street
Rockville, MD
Category: This is a Category 2 meeting. The public is invited to participate in this meeting by
discussing regulatory issues with the Nuclear Regulatory Commission (NRC) at
designated points identified on the agenda.
Purpose: To conduct a public meeting with the industry and staff to share each organization's
perspective on the Effectiveness of the Component Design Bases Inspections


Dec 10:
So I got a question, why after that first CDBI inspection didn’t the NRC tell Entergy if we find another “even one more CDBI violation” we will severely punish you with a prolonged shutdown. Why didn’t Entergy do heavy duty scrub on all their licensing and design issue so they never had another violation? 
How did it ever come to the point where it turned to it’s the NRC responsibility to find CDBI violations at Palisades?  
Personally I think Palisades has become obstinate over finding and correcting CDBI issues.
updated Dec 10:

How did we get here to a component design bases inspection? It came out of the Maine Yankee debacle. The regular inspector staff weren't catching all the violations...the NRC was forced to bring on a heavy duty inspection team for political reasons leading to uncovering a lot of missed violations and the premature shutdown of the plant.  
OCTOBER 3, 2007 

“Although the Commission is confident that the Reactor Oversight Process is superior to the Maine Yankee Independent Safety Assessment, we continue to improve the process. For example, in 2006, the NRC staff, at the direction of the Commission, significantly enhanced the way the NRC reviews design issues. The resulting Component Design Basis Inspection procedure, which is an important element of the Reactor Oversight Process, is a team inspection to verify that design bases have been correctly implemented for selected risk significant components and that operating procedures and operator actions are consistent with design and licensing bases.” 
Here is a list of NRC component design bases inspection report since 2007. That is when they must have started these inspections. So we got 30 design and licensing violations since 2006 ...the inability to ever meet their plant licensing commitments. 

I think it is the job of the engineering department and the NRC to provide a pristine licensing environment for the licensing operators up in the control room. More, the plant should be perfectly congruent with licensing and we should alway drive the plant licencing towards sustained safety. An operator walks into work for the day, all plant licensing conditions should be pristine and all of the engineering should make sure the components operate better than as designed. The plant needs to keep up in modernity. These staffs should dedicate their lives to support the operating staff. Always, if the plant had any transient or accident...basically in a accident, there should be no surprises with broken equipment and events should never occur outside the well worn path of plant licensing. There never should be any surprises for the operators in any accident and certainly we shouldn't have any events outside licensing and training...plant designs should always be informed with the lessons learned through the history of the plant and throughout the industry. Anything less is a abdication to the dedication of the operating crew...you are setting up the licensing staff to fail. So with any violation of the Maine Yankee Component Design Basis inspection you are screwing the operating staff.

So there were 30 CDBI violations over the course of the five CDBI inspections. Obviously the NRC was doing a political CDBI inspection…partial inspections with the phony idea of clearing out all Maine Yankee CDBI like violations at Palisades or any plant. A type of inspection the NRC implied they were doing would look like this; maybe 30 violations on the first inspection and maybe one or two each of the rest the inspections.
I don't understand why it takes a special CDBI inspection team…is the resident inspector prohibited with uncovering CDBI violations? You get it, the residents are artificially prohibited from being involved in CDBI, 50.59 and licences amendment request violation. They have to bring on a different set of NRC inspectors...I consider this as artificially limiting violations discovery and reporting.
The middle CDBI inspection in 2008, 2009 and 2011 with (4,2 and 4 violations ending in 11 violations in 2014) indicates the agency inappropriately limited the scope of the middle inspections or limited the number of violations the inspector could report in 2008, 2009 and 2011 time frame? 



Right, as the behavior of Palisades was worsening in the middle years of this, the NRC was loosening the screws on Palisades right up to the late Sept 2011 yellow finding DC accident. Palisades was perilously declining all through the prior year and continued on to the other side of the yellow finding and the NRC was looking at them through a inappropriately loosening lens. The NRC needed the high hurdle of a unexpected set of incidences, accidents and plant trips before they could intervene to stabilizes the plant.  
Was the NRC signaling regulatory laxity in the head winds of Palisades worsening behavior, in the lead up to Sept 2011? Was Entergy keying off that and destroying their plant safety culture?
If the agency took a really really hard stance on the CDBI violations…would Palisades have corrected their behavior way before Sept 2012 yellow finding?

These plants with all their components are tremendously complex and the majority of the safety components sit behind a barrier, with the components in operation we are mostly blinded...we can't see what is going on. Of even more complexity, all NRC and plant rules, policies, procedures and multiple organizational complexity. All of this in totality is really not understandable...can't be comprehensively understood in any information system provided to us. It is just the fact of life. At the bottom of this, it a easily apparent in this Palisades inspection and the totality of the component design inspection to date...the massive complexity dwarfs the capabilities of the staff of the NRc and Entergy. If the staff's resources dwarfed the complexity of system, all the known and unknown design component violations would have been cleared out of violations on the first inspection and their would have only been less than a handful after the first inspection to date. If the Palisades and NRC staff dwarfed the complexity of the system all through the design, construction and operations of the plant, then there never would have been the necessity of ever having a Component Design Basis Inspection violation at all...Maine Yankee would have been stall running and there would have never been such a thing as a CDBI.

You can’t understand how we go to the Component Design Basis Inspection and the 2007 commissioner Klein speech, unless you understand the nuclear industry's turmoil all throughout the 1990s and leading up to beyond the 2001 David Besse head problem. 
1992 -I got fired from VY for raising safety issues?  
Jan 1993 -President Clinton  
1993 -Paul Blanch leaves Millstone  
Nov 94 -midterms, house and senate now controlled by republicans  
1995 -Shirley Jackson becomes NRC chairman June 96 -Galantis leaves Millstone and three Units shutdown 
Nov 96 -Clinton reelected with 49% Dec 96 - Maine Yankee shuts down permanently  
Nov 97 -Commonwealth Edison's whole nuclear system on fire and burning in Chicago, largest owner of nuclear plants in nation 
*1998 -Permanent shutdown of two unit Zion  
1999 -Jackson run out of office 
July 1 -Jackson became president of Rensselaer Polytechnic Institute 
Jan 2001 -President Bush 
2002 –Davis Besse head
Do you know what complacency and negligence cost us, make bad actor pay the price with taking shortcuts... it massively drives up complexity not making one more kilowatt for our work. Think of the additional complexity Maine Yankee brought us, it was the symbol nationwide with licensees not maintaining the licensing conditions in their plants and there was tremendous amount of plant operational problems. Think of all the complexity the CDBI brings to us with a gaggle of inspectors dedicated to these inspections, the procedures of the NRC for this, all officials who manage this and the interaction with the licensee, and the effort of the licensees himself. Not one extra kilowatt is made from this. How much does negligence and ignorance really cost us? I think this is model with driving up most of the unnecessary complexity of the whole system...this is the price we a pay with a lesser perfection and the lack of appreciation of a beautiful world. This is the world that short term profits brings us and the quarterly financial reports. A beautiful world is a economical world on the long run, and god serves us all.    

Remember the complexity is so large, I believe the totality the NRC and Palisades staffs and our sampling regulator...we only see and clear a insignificant amount of the licensing and component/procedure defects. So we got 30 CDBI violations to date at Palisade, they must have cleared out a lot of violation before they invented the CDBI inspections and the Maine Yankee shutdown...what violation do we have left in the life of the Palisades? Maybe, thirty, fifty or a hundred... Who is to say, will they are catch all of them before end of life.

Yous see what the staff is facing with obsolete plant? Palisades has never been a pristine operational plant...this plant has been very troubled over decades. This never has been a pristine plant, they have been diry all their lives...this is not about nitpicking the plant on minor licensing and maintaining the quality of component issues here. 


Remember the profound troubles with Palisades and all this massive attention by the NRC to Palisades over the decades is a zero sum game, especially with limited NRC resources...it steals NRC resources from other plants. It allows other plants to decline unseen and get into big troubles. Actually, this is how the NRC explained their actions in Davis Besse. Other bad actors and troubled plants in region III blinded us to the decline of Davis Besse. The refrain was, our inadequate agency processes prevented us from seeing the true conditions of the Davis Besse staff, we through DB was one of the better running plants, we then stuck our extra resources into the other troubles region III plants. We didn't have adequate inspection services on the approach to DB hole in the head at the site and our overwhelmed inspection services and limited agency processes didn't allow the agency see the decline of the plant into the hole in the head.   

And we know, out the NRC's OIG report on San Onofre and events at Millstone, the lot of NRC officials up and down the levels of the NRC spoke over and over again about not having the capabilities to see the big picture because of a artificial ideological limitations on NRC inspection resources and their unconscionable sampling philosophy that only allows them to see less than 10% of the field of play with the little understood complexity of the technology and government. How we defaulted to this kind of regulator. You know that don't you; we are not just talking about the complexity of Palisades...basically the complexity of the NRC organization and their regulation and procedures. It is absolutely clear so much of this complexity is in the NRC itself and this dissociating caused by musical chairs in the commissioners office in recent years, one side of the NRC brain doesn't know what is in the other side of their brain, the hemispheres aren't talking and communicating with each other.   

Last cycle, what if they had a big accidents? In a accident, it really stresses the components and employees of the plant as never before. All of the 11 violation predisposes to the staff that lots of components will fail in a unexpectant manner in an accident. The violations might give inaccurate indication to the operator in the accident. All these violations and the ones not knowable and fixed, half blinds the operating crew. They are facing a indeterminate amount of failures and control room confusion in big accident. Do you think the staff is at the top of their game or dispirited and demoralized? That will play a huge part in this. A large proportion of the current and future violation are about detecting and correcting the declines of the components in a obsolete plant. I think we are here with a new kind of accident not acted upon by the NRC. Honestly, do you trust government...

I advocated replacing on a emergency bases the 20 oldest plants in the USA with new plants. You know what Fukushima tells us, it would have been tremendously more economical to replace the Daiichi plant and similar plants with new plants. Prior to the accident there just isn't enough money to replace the plant, after the accident it all looks like a once in a lifetime opportunity. You say it is too expensive and the burdens of doing it are too high a hurdle...history teaches us we have no idea what the true cost of complacency is. In the rear view mirror of history, we have wasted so much treasure and opportunity. Honestly, I know this is hard to swallow. i know the system has pretty much got us checkmated on shutting down dangerous plants...maybe if we gave them the opportunity of a future they would do the right thing. i think it is a lot more dangerous if we let the industry decay away as we envision it today. Inaction,complaceny and political gridlock cost us so much.              

I have recently talked to a NRC 50.59 expert in region 1, he reminded me the early plants had skimpily plant licensing and their documentation was atrocious. We should always be thinking of that with these old plants. Keep in mind, the NRC is a shallow sampling regulator. They pick a number sample set...we have no idea of the real size of the cohort of all violation known but not recorded or unknown. They choose what they want us to see so all in the interest of their altruism.

Basically for the most recent component design inspections, these aren't new violations. These are violations and licensing defects that have been mostly around for decades and many come from before the plants first startup. Is this the third world of Guatemala where we are too poor and corrupt to develop their infrastructure...or are we the reflection of the best and brightest nation on the planet. Who are we? We have so much capability and opportunity wasted.  
    
December 2, 2014 : SUBJECT: PALISADES NUCLEAR PLANT COMPONENT DESIGN BASES INSPECTION 05000255/2014008 
11 violations  
September 12, 2011 SUBJECT:PALISADES NUCLEAR PLANT COMPONENT DESIGN BASES INSPECTION AND TEMPORARY INSTRUCTION 2515/177, “MANAGING GAS ACCUMULATION IN EMERGENCY CORE COOLING,DECAY HEAT REMOVAL, AND CONTAINMENT SPRAY SYSTEMS REPORT” 05000255/2011009 
Four violations 
January 15, 2009: SUBJECT: PALISADES NUCLEAR PLANT NRC COMPONENT DESIGN BASES INSPECTION (CDBI) INSPECTION REPORT 05000255/2008009(DRS)
Two violations 

one violations
February 13, 2007 SUBJECT: PALISADES NUCLEAR PLANT NRC COMPONENT DESIGN BASES INSPECTION (CDBI) REPORT 05000255/2006009(DRS) 
11 violations

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. However, because of their very low safety significance, and because the issues were entered into your Corrective Action Program, the NRC is treating the issues as Non-Cited Violations (NCVs) in accordance with Section 2.3.2 of the NRC Enforcement Policy. Additionally, one licensee-identified violation is listed in Section 4OA7 of this report.
December 2, 2014: SUBJECT: PALISADES NUCLEAR PLANT COMPONENT DESIGN BASES INSPECTION 05000255/2014008
NRC-Identified and Self-Revealing Findings
Cornerstone: Initiating Events 
Green. The inspectors identified a finding having very low safety significance and an associated Non-Cited Violation (NCV) of 10 CFR Part 50.36(c)(3), “Surveillance Requirements,” for the failure to ensure the channel time delay for the degraded-voltage monitor was included in Technical Specification (TS) Surveillance Requirement (SR) 3.3.5.2.a. Specifically, the licensee failed to include in the TS SR the required time delay after the voltage relay trips before the preferred source of power is isolated and 1E electrical loads transferred to the stand-by Emergency Diesel Generators (EDGs). This finding was entered into the licensee’s Corrective Action Program and the licensee’s preliminary verification determined the degraded voltage monitors were still operable but degraded or non-conforming. 
NRC picture...is your gonads protected.


The performance deficiency was determined to be more than minor because if left uncorrected, it would have the potential to lead to more significant safety concern. Specifically, by not incorporating the total time delay requirements into the Technical Specifications, (TS) the time could be changed without going through the TS change process, possibly leading to spurious trips of offsite power sources or possibly exceeding the accident analysis time is the FSAR. The inspectors determined the finding was of very low safety significance (Green) because it did not cause a reactor trip and the loss of mitigation equipment relied upon to transition the plant from the onset of the trip to a stable shutdown condition. The inspectors did not identify a cross-cutting aspect associated with this finding because the finding was not representative of the licensee’s present performance. (Section 1R21.3.b(9)) 
Cornerstone: Mitigating Systems
Green. The inspectors identified a finding of very low safety significance and associated Non-Cited Violation of 10 CFR Part 50, Appendix B, Criterion III, “Design Control” for the failure to ensure the safety-related Engineered Safeguard Systems trains would not be adversely affected by air entrainment when aligned to the Safety Injection and Refueling Water (SIRW) Tank. Specifically, calculation EA-C-PAL-0877D, assumed incorrectly only one train of the Engineered Safeguards System (ESS) was in operation when evaluating if the SIRW Tank reaches the limit for critical submergence during a tank drawdown. As part of their corrective actions, the licensee re-evaluated the scenarios of concern, performed an operability evaluation, and implemented compensatory actions. 
The performance deficiency was determined to be more than minor because it impacted the Equipment Performance attribute of the Reactor Safety, Mitigating Systems Cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, air entrainment into the ESS systems could potentially impact the operability of the system by air binding the pumps, reduce discharge flow, discharge pressure and/or delay injection. The inspectors determined the finding was of very low safety significance (Green) because the finding was a deficiency affecting the design or qualification of a mitigating structure system or component (SSC) but the SSC maintained its operability. The inspectors did not identify a cross-cutting aspect associated with this finding because the finding was not representative of the licensee’s present performance. (Section 1R21.3.b(1)) 
Green. The inspectors identified a finding of very low safety significance and associated NCV of 10 CFR Part 50, Appendix B, Criterion III, “Design Control,” for the licensee’s failure to ensure the incoming feeder cables from startup transformer 1-2 to 2400 V safety-related Buses 1C and 1D were sized in accordance with their design basis, as described in Palisades FSAR Section 8.5.2. Specifically, the licensee failed to ensure the ampacity of the cables was at least as high as their maximum steady-state current. The licensee entered this finding into their Correction Action Program and verified the operability of the cables. 
The performance deficiency was determined to be more than minor, because it impacted the Design Control attribute of the Reactor Safety, Mitigating Systems Cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, cables were undersized with respect to the loading that would automatically occur as the result of a design basis accident. The inspectors determined the finding was of very low safety significance (Green) because the SSC maintained its operability and functionality. This finding had a crosscutting aspect in the area of Human Performance, associated with the Design Margin component, because the licensee did not ensure that equipment is operated and maintained within design margins, and margins are carefully guarded and changed only through a systematic and rigorous process. [H.6] (Section 1R21.3.b(2)) 
Green. The inspectors identified a finding of very low safety significance and associated NCV of 10 CFR Part 50, Appendix B, Criterion III, “Design Control,” for the licensee’s failure to ensure electric motors are sized in accordance with the design basis, as discussed in Palisades FSAR Section 6.2.3.1. Specifically, the horsepower ratings of certain motors are less than power demands of their driven equipment, and they were not analyzed to ensure overheating would not occur. The licensee entered this finding into their Correction Action Program with a recommended action to analyze the effect of the condition, and has verified the operability of the motors. 
This performance deficiency was determined to be more than minor, because it impacted the Design Control attribute of the Reactor Safety, Mitigating Systems Cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, motors serving loads with power demands in excess of the motor horsepower ratings were not analyzed to ensure that motor damage would not occur. The inspectors determined the finding was of very low safety significance (Green) because the SSC maintained its operability and functionality. This finding had a crosscutting aspect in the area of Human Performance, associated with the Design Margin component, because the licensee failed to ensure that equipment is operated within design margins, and margins are carefully guarded and changed only through a systematic and rigorous process. [H.6] (Section 1R21.3.b(3)) 
Green. The inspectors identified a finding of very low safety significance and associated NCV of 10 CFR Part 50, Appendix B, Criterion III, “Design Control,” for the licensee’s failure to ensure that voltages on the 480V system do not exceed equipment ratings. Specifically, the licensee increased the output voltage of the supply transformers to the 480V safety-related buses by 2.5 percent, but failed to ensure the resulting voltages would not exceed equipment ratings when the system is powered from the station power transformer or emergency diesel generator. The licensee entered this finding into their Correction Action Program and verified the operability of the affected equipment. 
The performance deficiency was determined to be more than minor, because it impacted the Design Control attribute of the Reactor Safety, Mitigating Systems Cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the licensee failed to verify or check the voltage increase on the 480V system to ensure the maximum allowable voltage would not exceed equipment ratings. The inspectors determined the finding was of very low safety significance (Green) because the affected SSCs maintained their operability and functionality. The inspectors did not identify a cross-cutting aspect associated with this finding, because the finding was not representative of the licensee’s present performance. (Section 1R21.3.b(4)) 
Green. The inspectors identified a finding of very low safety significance and associated Non-Cited Violation of Technical Specifications 5.5.7, "Inservice Testing Program," for the failure to perform comprehensive pump testing of Containment Spray Pump P-54A in accordance with the code of record. Specifically, the licensee did not rerun a comprehensive pump test, as required by the code’s ISTB-6300 “Systematic Error” section. As part of their corrective actions, the licensee entered the issue into the Corrective Action Program, and determined the component remained operable. 
The performance deficiency was determined to be more than minor because it impacted the Equipment Performance attribute of the Reactor Safety, Mitigating Systems Cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, failing to perform testing as required could result in the degradation of the equipment being undetected. The finding screened as having very low safety significance because the finding was a deficiency affecting the design or qualification of a mitigating structure system or component (SSC) but the SSC maintained its operability. The findings had a cross-cutting aspect in the area of Problem Identification and Resolution, Evaluation, because the licensee failed to thoroughly evaluate the issue to ensure that resolutions address causes and extents of conditions commensurate with their safety significance. [P.2] (Section 1R21.3.b(5)) 
Green. The inspectors identified a finding of very low safety significance and associated NCV of 10 CFR Part 50, Appendix B, Criterion XI, “Test Control,” for the licensee’s failure to have adequate acceptance criteria in the emergency diesel generator surveillance procedures. Specifically, the licensee failed to ensure the surveillance test procedures for the emergency diesel generator largest load rejection test bounded the power demand of the largest load, as required by Technical Specification SR 3.8.1.5. The licensee entered this finding into their Correction Action Program and verified the operability of the emergency diesel generators.
The performance deficiency was determined to be more than minor, because it impacted the Procedure Quality attribute of the Reactor Safety, Mitigating Systems Cornerstone and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems to respond to initiating events to prevent undesirable consequences. Specifically, the surveillance procedure error could result in acceptance of test results that did not satisfy Technical Specification SR 3.8.1.5 for rejection of a load greater than or equal to the emergency diesel generator’s single largest predicted post-accident load. The inspectors determined the finding was of very low safety significance (Green) because the SSC maintained its operability and functionality. This finding had a cross-cutting aspect in the area of Human Performance, associated with the Resources component, because the licensee failed to ensure that personnel, equipment, procedures, and other resources are adequate to assure nuclear safety by maintaining long term plant safety.  
[H.1] (Section 4OA2.1.b(1))
Cornerstone: Barrier Integrity
Green. The inspectors identified a finding of very low safety significance (Green) and associated NCV of 10 CFR Part 50, Appendix B, Criterion III, “Design Control,” for the licensee’s failure to correctly translate design valve leakage limits into the applicable test procedure. Specifically, the acceptance criterion for emergency core cooling system (ECCS)/containment spray (CS) recirculation isolation valves CV-3027 and CV-3056 had not been correctly adjusted to account for the higher differential pressure associated with ECCS operation under post-accident conditions. The licensee entered this finding into their Corrective Action Program to correct the valve leakage limit. 
The performance deficiency was determined to be more than minor because it impacted the Design Control attribute of the Barrier Integrity Cornerstone and adversely affected the associated cornerstone objective to provide reasonable assurance that containment could protect the public from radionuclide releases caused by accidents or events. Specifically, leakage approaching the procedural values would exceed analyzed dose calculations. The finding screened as of very low safety significance (Green) because the finding did not represent an actual open pathway in the physical integrity of reactor containment, containment isolation system, or heat removal components and did not involve an actual reduction in function of hydrogen igniters in the reactor containment. The inspectors determined this finding did not have an associated cross-cutting aspect because it was not representative of present performance. (Section 1R21.3.b(6)) 
Green. The inspectors identified a finding of very low safety significance (Green) and associated NCV of 10 CFR Part 50, Appendix B, Criterion VII, “Control of Purchased Material, Equipment, and Services,” for the licensee’s failure to identify non-safety-related sub-components improperly supplied with safety-related valves. Specifically, ECCS/CS recirculation isolation valves CV-3027 and CV-3056, which were installed in 2007, were supplied with non-safety-related sub-components. These components were identified as non-safety-related on the vendor drawings. In addition, the licensee later installed a section of non-safety-related tubing on valve CV-3027 based on the incorrect vendor drawing. The licensee entered this finding into their Corrective Action Program to correct the valve drawings and replace the non-safety-related parts. 
The performance deficiency was determined to be more than minor because it impacted the Design Control attribute of the Barrier Integrity Cornerstone and adversely affected the associated cornerstone objective to provide reasonable assurance that containment could protect the public from radionuclide releases caused by accidents or events. Specifically, the licensee failed to identify non-safety-related sub-components improperly supplied with safety-related valves which would form part of the containment barrier under post-accident conditions. The finding screened as of very low safety significance (Green) because the finding did not represent an actual open pathway in the physical integrity of reactor containment, containment isolation system, or heat removal components and did not involve an actual reduction in function of hydrogen igniters in the reactor containment. The inspectors determined this finding did not have an associated cross-cutting aspect because it was not representative of the licensee’s present performance. (Section 1R21.3.b(7)) 
Green. The inspectors identified a finding of very low safety significance and associated NCV of 10 CFR Part 50, Appendix B, Criterion XI, “Test Control,” for the licensee’s failure to establish an adequate test program for the Shutdown Cooling (SDC) Heat Exchangers (HXs) to demonstrate they can perform as designed. Specifically, the licensee failed to take actions to ensure the SDC HXs’ heat transfer capability met its design bases, as assumed in design bases calculations. 
The performance deficiency was determined to be more than minor because it impacted the Design Control attribute of the Barrier Integrity Cornerstone and adversely affected the associated cornerstone objective to provide reasonable assurance that containment could protect the public from radionuclide releases caused by accidents or events. Specifically, the licensee failed to verify the SDC HXs heat transfer capability met their design bases, as assumed in design bases calculations, to limit containment temperatures and pressures during an event. The finding screened as of very low safety significance (Green) because the finding did not represent an actual open pathway in the physical integrity of reactor containment, containment isolation system, or heat removal components and did not involve an actual reduction in function of hydrogen igniters in the reactor containment. The inspectors determined this finding had an associated cross-cutting aspect, Conservative Bias, in the Human Performance cross-cutting area. Specifically, on several occasions when the licensee identified the need to perform testing and/or inspection of the SDC HXs, the licensee did not take actions because they did not believe any regulatory requirements or technical issues existed that required the testing and/or inspections. [H.14] (Section 1R21.3.b(8)) 
B. Licensee-Identified Violations
Violations of very low safety or security significance or Severity Level IV that were identified by the licensee have been reviewed by the NRC. Corrective actions taken or planned by the licensee have been entered into the licensee’s Corrective Action Program (CAP). These violations and CAP tracking numbers are listed in Section 4OA7 of this report.

Monday, December 08, 2014

NRC Checking if Gonads protected With Titanium Vest On Employees at Palisades (offical NRC pictures).



Entergy-Palisades replaced leaking CRMD housings more often than you change the oil in your car. To do this job, they take off the reactor vessel head and place it aside on the refueling floor. It is pretty radioactivity hot job and I think they are in respirators. They had lots of preventable fuel failures in the recent past and that makes this job particularly radioactivity hot.
Hmm, does these employees feel so insecure about the high radiation levels, the "not required vest" acts as a toddler blanket comforter?
Is it for beta or alpha protection?  
The below translated, Entergy said these titanium vest gave them more protection than they actually provided...meaning Palisades put down on the paperwork for these employees a radiation dose lower than what they actually got. They collectively got 98 rems more dose than what they first put down on paperwork. I am wondering of the HP contractor talked Entergy into this artificial titanium shield reduction in dose...hey, you can report your dose to the NRC lower than it actually is. How much of this titanium dose crap is going on throughout the industry. Palisades and Entergy is supposed to have highly educated and experience professional people on their staff such that this never could occur.
Well, it is a lot more complicated than I stated it. It is basically they got a tremendous radiation gradient, if they put  radiation detectors in the upper chest and their ass is sitting on a hot spot without a detector there…the dose detected is not accurate. Their fingers might be taking off a nut in a hot zone, with the rest of the body not being in that field. They basically got computer programs that can take these peripheral reading and come up with a whole dose.  
That reactor head and its control rod drive mechanism was defective and obsolete since the first day that reactor came into operation. Palisades should have designed, manufactured and installed a new head and CDRM package decades ago. But they been always been crying poor boy and one step away from permanent shutdown.
See, you can’t see this in its proper context. I bitterly complained about the dangerous and poorly designed primary coolant pumps during this very same outage. The NRC has been letting them get away with operating not according to plant designs and licensing for decades…thus causing impeller blades to fly out of the housing and get flung all around the coolant and stuck in areas in the reactor.
 It is like the tire nuts on your right front wheel being loose and you feel front end shaking as you drive the car. The NRC says this it is safe to drive until you get to the next oil change. If the NRC allows 100 nuclear plants to operate with that kind of attitude, then our nation is in deep trouble when eventually one plant pops its cork. 

Basically this is a slap on the wrist of Entergy having no meaning to interrupt the work on the CRDM job. This happened around early this year in Feb/Mar...why is this inspection report especially so late? Typically the NRC makes these reports like this, it is harmless to the big boy players… but it acts as protection against somebody calling it as a cover-up. This is how you do cover ups today…disclose it as a shield against somebody calling it coverup in in the future. It is corruption and cover-up protection. It is pretty smart really.

These guys are on artificial respiration and one breath away from a permanent plant shutdown…the NRC now has a policy to handle these guys with kit gloves..
December 2, 2014

EA-14-168

SUBJECT: PALISADES NUCLEAR PLANT, NRC INSPECTION REPORT 05000255/2014010, PRELIMINARY WHITE FINDING

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-2014-04683.
Definitely gonads not protected.

What’s the NRC’s proof that body got gonads?