Hinsdale, NH/Brattleboro, Vt Gets New Route 119 Bridge

Update 5/28

I am disappointed the local newspapers didn't write up a story about the bridge getting past the NH House and Senate.

***If we name it the "Mike Mulligan Memorial Bridge" (or something), I'll promise I will use the attention to shine a light over our dangerous national transportation infrastructure problems. You people own me $1500 dollars in court cost and fines!

Here is me holding a hunk of rust from the bridge. I love this youtube of me:   


You see the irony here, "the teabagger I hate the government state of New Hampshire" is using federal funding for their state roads. Basically underfund state government, then get the feds to pay your bills, all the while on the way to the bank bad mouthing government is the root of all our society's problems.

What is this, about a $40 million dollar bridge?     

May 26. 2016 11:46PM State highway improvement plan approved
By GARRY RAYNO
State House Bureau

CONCORD — House and Senate negotiators agreed Thursday on the nearly $4 billion, 10-year highway plan that includes money to pave a fourth lane for both barrels of Interstate 93 between Manchester and Salem, but nothing for commuter rail.

House Bill 2016 would use Grant Anticipation Revenue Vehicles (GARVE) bonds to fund two bridge projects over the Connecticut River, the Route 119 bridge between Hinsdale and Brattleboro, Vt., and the I-89 bridge between Lebanon and White River Junction, Vt.

This is the real story about getting our new bridge. I was dressed up as a angel with a halo on my head as a attention seeking device for years, as I was protesting to get this new bridge. Ouch: it was painful at times. I had a lot of fun with bridge protesting until the police got involved with me.

The big picture of the Hinsdale police involvement with me is they were doing their job and they were decent to me. I was very disappointed with the District courts. The court system reminded me of NH roads and bridge funding problem, basically underfunded and a poor system. My day of arrangement, the collage kids had a party and about a hundred of them got arrested. They are all in court on my arrangement day. It was chaos in there. I got confused with the clerk's instruction, as did most everyone else. I left before they officially arranged me. You would think they would give me a call to finish it. Two days later, I called the prosecutor to see how much information they could give me. The secretary said we got a warrant out on you and the police are trying to arrest you. I said ok, I will go to the police station. Is there anyway we can take care of this between me and you. She said wait a second. She came back saying you promise to show up in court next Monday, fine I said. I'll be there. She then told me the warrant has been lifted.

On a Friday early evening, a Hinsdale cop came to the door saying I here to arrest you. They wanted me in jail over the weekend as punishment for embarrassing the town. He showed me the warrant. I told cop the warrant is no good with a smirk. The cop laughed at me saying, you think I haven't heard that before this. If I had my wits on me, I should have just seen how far I could get into the jail intake process with a bad warrant. It would have been a great newspaper article. The cop told me he never seen a bad...rescinded-warrant in his career I explained what happened in court and I had talked to the prosecutor. He gave the courts a call, they told him I have no outstanding warrants. The cop was shocked with that. He kept saying, "I was going to arrest a guy on a bad warrant" over and over again. This cop was a good guy. He explained they received the warrant on Wednesday, they just got around to make the arrest. That is my grounds for the chief engineered the timing to hurt me the most. It is an old police trick to punish somebody outside the courts. The stupid police never made a final check to see if the warrant was still good. When you get into the district court system, its like you entered a undecipherable black hole. It is unbelievable the power of the cops and courts have to force you to settle any case.


I visited  the court three times, for hours at time, in the months before the arrangement. The court is a really interesting place. They are way more interesting than any tv program. I wanted to reduce my nervousness for the arrangement day. It didn't work.               

Brattleboro Reformer Clears The Air Over Court Plea by "Angel Guy"

The front page of this below article has a picture of me with a halo on my head. I always got a halo around my head, but most times you can't see it.  At this point with The Commons story, it was very iffy we would get a new bridge in the next fifty years. NH is a terrible state because government is severely underfunded. I will make case, systemically the state police and the local police are severely underfunded and screaming for more training.  We had come to this point of the process many times in the past with the bridge and the proposed new bridge was later thrown overboard in the later stages of the legislative process.    

A Cause For Concern 

Self-appointed “bridge angel” and whistleblower Michael Mulligan of Hinsdale, replete with a handmade halo, held pieces of rusted bridge above his head and proclaimed the bridges unsafe. 

“How do we really know these bridges are going to last another 50 years?” he said.  

Mulligan also asserted that the New Hampshire government had “falsified” documents regarding the bridges’ safety, were “baloneying the people,” and could not be trusted.
“You cannot trust the state to do an inspection,” Mulligan said. 

The two existing Pennsylvania truss bridges, the Charles Dana and Anna Hunt Marsh, were erected in 1920, and were upgraded in 1988, according to bridge inspection reports.

and 

"That is inaccurate. About 8 pm I completed making safe the walkway on the Charles Dana Bridge. I had put up substantial safety barriers, the Hinsdale police approved my barriers by putting up police tape without restructuring my the barrier to make it more safer. To document my activities, I called 911 before 9 pm. I reported the condition of the bridge and what I did...they directed the call to a Hinsdale police officer. I notified him what I did, he assured me a policeman was on the scene. He told me Hinsdale police department was overloaded...but the Brattleboro police were on scene and doing an investigation...

I made sure within an hour of my activities at bridge the site was investigated for safety’s sake by the police and they had approved my safety barriers."

Another irony here is we are getting a new bridge and new owners of the Brattleboro Reformer newspaper at about the same timeframe. It is the same old bridge on the Connecticut river and still the same old dysfunctional newspaper today.  

My poor wife and family having to tolerate a guy like me :)

Going to jail humor:  

The MTA song. 
(The Kingston Trio) The MJM song.

Let me tell you the story
Of a man named Mike
On a tragic and fateful day
He pulled up ten boards on a bridge
Kissed his wife and family
Went to ride on his bike.
　Chorus:
Or else he'll never return,
No he'll never return
And his fate will be unlearned
He may ride forever
On the streets of Hinsdale
He's the man (Who's the man)He's the man (Oh, the man)He's the man who never returned

Tell you the truth, the new Brattleboro Williams Street I 91 new bridge project (exit 2) took me about 6 years to complete. I had taken horrible pictures of the bridge concrete piers. They had cancer on them. They built a temporary iron beam structure around the dangerous concrete piers. The temporary beams through neglect were rusted through. I had some really beautiful ugly pictures, if you know what I mean. I had extensively investigated, during a snow storm, a simi tractor trailer lost control on the bridge and slid right through the bridge tinfoil railing falling 30 feet to his death. The William Street I 91 Daddy killer bridge as I called it. I was once a truck driver. The bridge was built defective and unsafe from the get go in the early 1960s. The whole deal of how the USA developed our roads and interstate highway system is tremendously fascinating and interesting to me. Through this accident on the interstate bridge, I vowed over this, I would replace the bridge. So I pictured up this beautiful ugly ugly bridge and began a campaign with Vermont DOT officials to make their lives miserable.

I tell further on the big picture, when are we ever going to get the mega newspapers/media conglomerates on our side? When are they going to start fighting for the little people? When are they going to speak for the little people's interest. The news media in all their forms, is really a humongous societal infrastructure system. It wholly supports all of the living. As with our roads and highways, we can't live without a healthy news media interstate infrastructure system. We got obsolete, damaged and unsafe bridges and roads sprinkled all over our interstate news media infrastructure system.   

By the way, if I was president and being confronted by a early Afghanistan/Iraq issue, here is how I would handle it. I'd build a vast highway interstate system under military gunpoint in the targeted country. It would be my highest priority. We'd be a nation of road builders world wide. That is how you do efficient nation building. My primary military weapon would be building highways and societal interconnections. I stuff it down their throats by gunpoint. It would be my hydrogen bomb. I would wipe out anyone trying to stop and slow me down.          

The Hinsdale/Brattleboro route 119 new bridge took me a little longer and I had to work much harder for it. We are only talking about a combined $80 million dollar project. Do a search of me on Ibrat? The I 91 Daddy killer bridge.

Big picture, it is easier than you think getting a dangerous bridge replaced with our highly vulnerable politicians and state bureaucrats and our amazing connectivity. it is a really cheap project money wise. It is a multiyear project. You have to stay focused on your project and keep hounding everyone. Think of out of the box attention getting strategies. You have to choke down all the time the thought you are just a little guy and nothing ever changes. It is almost like a special insanity. You have to go contrary to the instinctual thoughts spinning in your head that nothing matters and you know you are so powerless. You have been powerless all you life, what makes you think this time anything will be different.

You just have to become comfortable with idea that numerous people in you community (and family) are going to tell you are a whack job and have a serous mental illness. Some people say it with a wide open smile and others are dead serous and screaming it at you. Boy, people telling you or the fear of a group people believing you have a serous mental illness, what a horrible stigma the label mental illness has on you. Out of this whole deal, that is the gift god gave me. I really don't care what anyone thinks about my mental status. You haven't completely disconnected me from the world yet. I would intently listen to anyone who approach me in a nice way, saying this is why I think you have mental issue. Nobody in my immediate family thinks I have a serous mental issue or have abnormal relationship issues, but he clearly does have his "issues". Big issues. Just like all the rest of us. My family all know me as a caring and loving person, but I am off a little bit. Weird on some issues. I work very hard to make this persona.

As a note, we don't allow guns in our house. I worked very hard over the years to notify the police I don't own guns. Especially when you get them pissed at you and are involved in a action that embarrasses the community. Guns are ok for the police and military, but I think anyone who owns a gun in the USA is basically a coward. Gun owners are all little people who need a gun to think they are powerful people. You see what I am saying, whistleblowers always have the issues of you might be violent, be a extreme right winger with a boat load of guns and under a severe mental illness swirling all around their lives. All the cops first think that. You have to really work hard on the police with showing them you got something going on upstairs and you are going to be non violent towards them.  We are constantly confronted with these issues over their lives. Be in the shadows of wondering if something mental is wrong with you. I am pretty sure I can handle a host of difficult situations in my life today, can see when I am starting to become unraveled. I know my emotional life a lot better now than when I started. The whole painful and playful deal has moved me better towards a more enlighten position. If I had money and real power I'd be hell on wheels:)

Remember, we never die: we just change energy forms. I think we live many lives and are just in the middle of this process. I think we got filaments of all our past and future lives embedded in our spirits and DNA. Science backs me up on my interpretation. How many universes are there? Science says an infinite amount and dimensions...they are all going on simultaneously. They say time isn't sequential...our interpretation of time is a god given illusion. The scientist say all of time everywhere occurs simultaneously. Mass just gives us the illusion time happens sequentially microsecond by microsecond. I think earth is really a training planet. More people call our planet a prison. I think reality is preparing us for something bigger. Because of this, I think we should savior every second we got on planet earth. Every breath! Earth is God's individual training program and he has got big plans for all of us in future. Or I could just be garden variety nuts like most think I am.     

               
Me on a youtube vedio: it is harder than you think to portray a issue on video. He interviewed me off the cuff on his cell phone. I thought he was approaching me to panhandle me.    

Junk Plant Monticello: Corrupt Root Cause Analysis All Over The Place

(05000263: this is a very old and obsolete plant)

LER 2016-01-00, "High Pressure Coolant Injection System Cracked Pipe Nipple Caused Oil Leak"

Presumably these plants have up to five million parts and components in these plants. What if they treated all the components like this?

I consider this a regulatory failure and it indicates a profound weakness in the NRC. The NRC should have made them fix the “tolerant of leaks problem” before the oil pipe burst.

I consider this a regulatory failure and it indicates a profound weakness in the NRC. The NRC should have made them fix the “tolerant of leaks problem” before the HPCI oil pipe burst. It sounds like they got a maintenance prioritization problem. This problem might be much more widespread. It sounds like they are becoming overwhelmed with unfixed maintenance problems at the plant.  

This plant is undergoing extreme financial stress. These guys recently bungled a extremely expensive power uprate and the state regulators denied full founding of the billion dollar upgrade. Excel is mortgaged to the hilt. Excel only owns one nuclear plant and it is a single plant site. The NEI says a plant like this is extraordinarily financially vulnerable. It worries me Monticello is pulling a Fort Calhoun. They spend a ton of money on the plant just before they turn off the lights. Excel is a weak electric utility.  

High Pressure Coolant Injection System Cracked Pipe Nipple Caused Oil Leak \

The High Pressure Coolant Injection (HPCI) system was inoperable during a pre-planned maintenance activity when a significant oil leak in HPCI system oil piping occurred because of a cracked oil pipe nipple. The leak was of sufficient size that if it occurred outside the pre-planned maintenance, HPCI would have been declared inoperable. The organizational root cause was that management and individuals were tolerant of leaks on the HPCI system. As a result, station personnel did not effectively advocate prompt repair of the HPCI oil leak. An organizational root cause evaluation was completed to address the assessment and prioritization of repair of known oil leaks on the HPCI system. The root cause determined that management and individuals were tolerant of leaks on the HPCI system. As a result, station personnel did not effectively advocate prompt repair of the HPCI oil leak.

Results of the extent of condition review identified two other pipe nipples and two elbows with thread leakage (no crack present)

This below is basically RCA malpractice and fraud. A competent investigator or evaluator would focus all his attention on the maintenance prioritization system problem.  This mindset is very dangerous!!! Is the evaluator intimidated by management into going into the more valuable deeper and expensive causes? 

An extent of condition was completed for all known leaks for the HPCI oil pipe system.

See, they treat HPCI historically like shit. The NRC did a "detailed" inspection of HPCI in late 2015. Why did he miss the leaking oil?

May 8, 2015  

SUBJECT: MONTICELLO NUCLEAR GENERATING PLANT NRC INTEGRATED AND POWER UPRATE INSPECTION REPORT 05000263/2015001 

Green. The inspectors identified a finding of very low safety significance and an NCV of 10 CFR Part 50, Appendix B, Criterion XVI, “Corrective Action,” for the licensee’s failure to promptly identify conditions adverse to quality, such as deficiencies, deviations, and nonconformances. Specifically, on February 11, 2015, the inspectors identified a safety related seismic support for high pressure coolant injection (HPCI) turbine trip instrumentation that was not rigidly attached, supported, and restrained in accordancewith plant construction code and installation specifications, a nonconformance which the licensee had failed to identify since initial plant construction. Corrective actions for this issue included repairs to the seismic support to rigidly connect the instrument line restraint and installation of a standalone support for the instrument tray. This issue was entered into the licensee’s corrective action program (CAP 1465906).

Oh, this plant is a struggling and the weak little buddy for the NRC. They got these guys under the arms of the NRC.

Lots of initial plant licencing problems the agency is just catching now.

My bad, Xcel owns more than one nuclear power plant. Praire Island is a very trouble site.

RED WING, Minn. -- Xcel Energy is awaiting word from the Minnesota Public Utilities Commission to proceed with an 18-month study on the future of Prairie Island nuclear plant and the economics of potentially shutting down the two-reactor facility before its operating license expires in 2034.

   

Junk Plant Indian Point MSSV, New Failure and My 2.206

Nobody ever answered my question: why did the inaccuracy setpoint failure rate take off in 2009? You have to assume the vibration of the piping on the steamline where the MSSV located is increasing?    

Indian Point 2.206: Runaway Main Steam Safety Valve Breakdowns Beginning In 2009 

The NRC must have guessed problem was solved with modification. Kinda gutsy move on the NRC's part. Wonder if abnormal degradation was seen in the other valves but not reported. I still think as the vibration damage builds in with these guys it will start not passing their test.

NRC 2.206 Response: Junk Safety Valves At Indian Point 

The good new is only one valve failed testing and it was one of the few valves without the modifications.

The bad news is it takes from 2011 to fully carry out a component safety modification...its pathetic.    

Technical Specification Prohibited Condition Caused by One Main Steam Safety Valve Outside Its As-Found Lift Set Point Test Acceptance Criteria

Licensee Event Report# 2016-001-00 Unit 2 

On March 4, 2016, during the performance of surveillance procedure 2-PT-R006, Main Steam Safety Valve (MSSV) MS-45B failed to lift within the Technical Specification (TS) as found required range of +/- 3% of the setpoint pressure. Valve MS-45B lifted at 1125 psig, 29 psig outside its acceptance range of 1034 to 1096 psig and 5.7% above its 1065 psig setpoint. The valve was declared inoperable, then subsequently restored to operability upon two successful lifts within the required setpoint range without the need for adjustment. Nine other MSSVs that were tested lifted within the as-found required setpoint range. The apparent cause for the failure was internal friction due to spindle rod wear, which causes the spindle rod to bind against internal components. Corrective actions were modification of MS-45B and twelve other MSSVs, and the replacement of their spindle rods. The event had no effect on public health and safety. 

The Energy Industry Identification System Codes are identified within the brackets {}. 

DESCRIPTION OF EVENT 

On March 4, 2016 at 1116 hours, while at approximately 79 percent power, during surveillance testing of the Main Steam Safety Valves (MSSV) in accordance with procedure 2-PT-R006, MSSV MS-45B on Steam Generator (SG) 22 failed to lift within the Technical Specification (TS) as-found required range of+/- 3% of the required setpoint pressure. Valve MS~45B lifted at 1125 psig, 29 psig outside its setpoint range of 1034 to 1096 psig and 5.7% above its 1065 psig setpoint. Consequently, MS-45B was declared inoperable and Technical Specification (TS) 3.7.1 (Main Steam Safety Valves) Condition A was entered. Two immediate subsequent

This was a dangerous safety component operability determination. They are using incomplete information saying the satisfactory lift pressure test proves the valves capably of doing their safety function. Later valve damage discovered proves the valve was inoperable. The call, the valve was operable, was just not conservative.

tests were performed without any adjustments required and the valve lifted at 1038 psig and 1037 psig. With the valve lifting within the required setpoint range, the valve was restored to operability, allowing exit from the TS 3.7.1 Action Statement at 1126 hours. During the surveillance test, nine (9) other MSSVs that were tested passed their as found test criteria and were left within the+/- 1% set point criteria. The failure of MS-45B was recorded in the Indian Point Energy Center (IPEC) Corrective Action Program (CAP) as Condition Report CR-IP2-2016-01204. 

During the performance of the 6-year Internal Inspection Preventive Maintenance (PM) activity on MS-45B completed on March 31, 2016 during refueling outage 2R22, numerous dimensions, clearances, and tolerances were verified and internal components were inspected for wear/damage. The valve spindle rod was found to have areas of wear along its length and around the circumference in the form of small steps, which is attributed to system vibration during power operation. All other inspection criteria were satisfactory.

There are five code safety valves (MSSVs) and one atmospheric dump valve (ADV) {RV} on each main steam (MS) line outside the Reactor Containment {NH} and upstream of the MS isolation valves {ISV}. The MSSVs consist of four- 6-inch by 10-inch and one 6-inch by 8-inch valve per SG ort each of four MS lines for a total of 20 valves. The five valves 'on each steam line are nominally set to open at 1065, 1080, 1095, 1110, and 1120 psig. The MSSVs are ASME Code relief valves, manufactured by Crosby-Ashton {C710}. Valve MS-45B is a 6-inch by 8-inch Model HA-65W Safety Valve.

The apparent cause for the failure was internal friction due to spindle rod wear, which causes the spindle rod to bind against internal components. High vibrations of the spindle rod caused friction between the rod, spring washer, and adjusting bolt. The vibration of the spindle rod while in contact with the spring washer and adjusting bolt resulted in severe wear in the form of steps on the spindle rod. The resulting frictional force occurs on the first lift and then does not repeat. 

The vendor's solution to the problem is to install sacrificial bronze wear sleeves along the inner diameter of the spindle rod contact points (inner diameters of the adjusting bolt, upper spring washer, and lower spring washer). The spring washers and adjusting bolt are machined to accept the bronze wear sleeves, which act as a sacrificial metal, preventing spindle wear and step formation. One sleeve is installed in each of the spring washers and two sleeves are installed in the adjusting bolt. 

An extent of condition (EOC) was performed to determine where potential conditions with similar valves, design, systems, and environments could occur. The review determined that the EOC found in the failure of MS-45B is restricted to the other 19 MSSVs at Unit 2 and the 20 MSSVs at Unit 3 due to the exclusive valve design. All MSSVs are exposed to high vibrations during their operating cycle during which wear can occur. Previous failures of MSSVs have included wear due to spring skewing and-setpoint drift. Spring skewing can occur in any of the MSSVs and cause side loading frictional forces which prevent the valve from lifting. Setpoint drift can occur due to age of the components and the operating cycle it is exposed to (e.g., changes in temperature, pressure and vibrations). 

PAST SIMILAR EVENTS 

A-review was performed of Licensee Event Reports (LERs) for any events rep9rting TS prohibited conditions due to MSSV test failures. LER 2010-002 reported two MSSV failures, one due to valve spring skew and the other due to setpoint drift. LER 2012-005 report~d one MSSV outside the required as-found lift setpoint range due to spring skew/spindle wear. 

The MSSVs at Unit 2 are the same as those at Unit 3, and LERs have reported MSSV test failures at Unit 3. LER-2011-004 reported two MSSVs outside the required as found lift setpoint ranges due to spindle wear and spring skew. LER-2013-001 reported two MSSVs outside the required as-found lift setpoint ranges due to galling around the circumference of the spindle rod as a result of vibration for one valve, and internal friction caused by foreign material between the guide bearing and spindle for the other valve. LER 2015-002 reported three MSSVs outside the required as-found lift setpoint ranges due to internal friction from spindle rod vibration. 

CORRECTIVE ACTIONS 

A modification was initiated in 2011 to install bronze wear sleeves in the upper and lower spring washers and the adjusting bolt as a solution to valve spring skew and spindle wear for the IPEC MSSVs. This modification was completed for 7 of the 20 Unit 2 MSSVs in the 2014 refueling outage (2R21). Valve MS-45B and the 12 other MSSVs that were not modified in 2R21 were modified in the 2016 refueling outage (2R22). New spindles were also installed in these 13 MSSVs in .2R22. All 20 MSSVs have been modified with the bronze wear sleeves. 

EVENT ANALYSIS 

The event is reportable under 10CFR50.73(a) (2) (i) (B). The licensee shall report any operation or condition which was prohibited by the plant TS. TS 3.7.1 (Main Steam Safety Valves) requires the MSSVs to be operable ·in accordance with TS Tables· 3. 7 .1-1 and 3.7.1-2. The applicable accident/transient analyses require five MSSVs per SG to provide overpressure protection for design basis transients occurring at 102% reactor thermal power. The MSSVs also provide a heat sink for the Reactor Coolant System if the Main Condenser is unavailable and the ADVs cannot relieve steam line pressure. 

Operability of the MSSVs is defined as the ability to open within the setpoint range, relieve SG overpressure, and reseat when pressure has been reduced, and is determined by periodic surveillance testing.. TS Surveillance Requirement (SR) 3. 7 .1.1 requires that each MSSV be verified to lift at its required setpoint per Table 3.7.1-2 in accordance with the Inservice Testing Program (IST). On March 4, 2016, MSSV valve MS-45B was found outside its required setpoint range, therefore, it failed its as found testing criteria and was declared inoperable. The valve was disassembled and inspected and determined to have conditions preventing proper operation. 'The apparent cause determined that failure was due to internal friction caused by spindle rod wear from vibration during the operating cycle. Spindle wear is not normal drift, therefore, the valve may have been inoperable during past operation. As it is not possible to determine when the valve would not have lifted within its required setpoint range, the valve was concluded to be inoperable for greater than the TS allowed completion time. An evaluation of applicable accident/transient analyses was performed to determine the impact of one MSSV with a higher opening setpoint. The evaluation concluded the condition would not have resulted in a loss of ·safety function. Therefore, this condition is not reportable under lOCFRSO. 7.3 (a) (2) (v) as a safety system functional failure.

Junk Plant Palisades and a Failed NRC Again

You know what they call insanity. Doing the same bad thing over and over with with expecting a different outcome. Palisades and Entergy must hold the world record holder with confirmatory orders and fleet wide ethical training that never works. The NRC should have picked up the fraud and falsification much earlier. Palisades have many layers of more educated and experiance employees overseeing these guys charged by the NRC. The more senior managers must have ordered the fraud or turned their eyes away from it. The fraud and falsification was systemic at the plant and organization.

The NRC's violation determination level for falsification and fraud is set way too low in their risk determinations. They should have been ordered to shutdown immediately, a red finding and not start-up till all the penalties were set and understood. The whole stream of management should have been fired. They guys should have gone to court and gotten in excess of ten years. It takes too much legal unobtainable proof to put these nuke guys in jail. The laws are so weak and the public at large is too stupid in the juries to convict these guys.  They are a protected class of people by congress. The process takes too long to get any real public justice and cause real deterrence to the workers, Palisades without a doubt, was a corrupt runaway rough operation for many years.

Bottom line, the employees "may" have lost their careers. Palisades got a measly one or two month shutdown to replace most of the safety tank. Mere pennies to these big guys. The little guys paid the big price. I hold Entergy much more responsible for sustaining a grossly rule breaking and unethical organization. This whole deal is another example of the captured NRC. Most of the Entergy fleet continues to intentionally not follow the rules and intentionally not make accurate safety degradation determinations to boost capacity. 

If the NRC hit hard Entergy squarely on the head with a sledge hammer, a death, near death experience and deterrence to all the nukes...most of the current serious set of violations fleet wouldn't have occurred since 2011. This would have saved Entergy and the NRC a tremindus amount of money and risk. The resources of the NRC and Entergy were wasted on these event. They are getting overwhelmed. They could have spent a lot of money on little events, not getting to these blockbuster event turning  the public perception against the industry.

Bottom line, there was no doubt there was federal corruption with overseeing this plant. The NRC staff and their bosses should have faced the courts and gone to jail. The length of this ADR indicates a deep continued cover-up. Can you believe it, they don't even get a oversight violation over this. Remember when they tore apart the safety tank, the tank was constructed contrary to plant licensing designs.  

There is going to be a day of reckoning with this level of blatant corruption. 

Do you get it, these sleazy word games both with the NRC and licencee, the selective enforcement of the rules and agreed upon codes, are tremendously intimidating to the licence staff at a power plant. I doubt today outsiders, and even NRC staff, gets the real take of safety culture at a plant from the intimidated staff.     

NRC Issues Confirmatory Order to Entergy Regarding Palisades Nuclear Plant 

The Nuclear Regulatory Commission has issued a Confirmatory Order to Entergy Nuclear Operations Inc. under which the company will perform a series of actions to address failures in handling a leak from the safety injection refueling water tank (SIRWT) into the control room at the Palisades Nuclear Plant. 

The plant is located in Covert, Mich., five miles south of South Haven. 

The order stems from a settlement reached under the NRC’s alternative dispute resolution (ADR) process requested by plant-owner Entergy to address the violations identified in the NRC’s investigation. The violations are connected to the discovery of leakage from the plant’s control room ceiling on May 18, 2011. 

Even though the leak did not result in damage to control room or other safety equipment, the NRC determined that four Palisades employees willfully failed to enter information which identified the tank as the source of the control room leak into the corrective actions program. This delayed Entergy’s response to the issue. In addition, Entergy failed to perform an adequate analysis of the tank’s ability to fulfill its safety function, and failed to follow requirements associated with a missed tank surveillance test. The tank is designed to provide borated water to cool the reactor in case of an accident. 

Entergy has already taken a number of actions to address the causes of the violations, which include repairs to the tank to prevent further leakage and strengthening the safety culture at Palisades. The NRC independently reviewed the company’s efforts and noted improvement in these areas. 

As a result of the ADR meeting, the company agreed to a number of additional commitments to improve its safety culture. These commitments include: ensuring personnel at Palisades and other Entergy fleet facilities understand lessons learned from this matter; sharing these insights with other nuclear plants; and reviewing applicable procedures. In addition to addressing programmatic and operational issues, the company agreed to modify its interactions with the public on Palisades. Those commitments include: conducting five public meetings by the end of 2018; inviting key stakeholders, such as concerned individuals, non-government organizations, federal, state and local officials to these meetings; focusing meeting discussion on plant safety and operation; and adopting a meeting format which allows members of the public to raise questions and concerns. 

The ADR process includes mediation facilitated by a neutral third party, with no decision making authority, who assists the NRC and a licensee in reaching an agreement when there are differences regarding an enforcement action. 

“Using the ADR process allowed us to achieve not only compliance with NRC requirements, but a wide range of corrective actions that go beyond those the agency may get through the traditional enforcement process,” said NRC Region III Administrator Cynthia Pederson. “The company will be reporting to the NRC as they are implementing the corrective actions. After Entergy notifies us in writing that they have fully met the conditions of the order, we will conduct an independent review and assessment of the company’s compliance with the order commitments.”

Summing Up The Current Pilgrim Plant Experience in 2013

What do you think about my 2013 blog comment? What do you think about it in today's May 2016 hind sight on all that we now now? I was prophetic? I'd seen the future. It happened as I said in 2013! In 2013, they kept from us the dire state of the meteorological towers at the Pilgrim. It took many more tower failures for the agency to admit both towers and their instrumentation were broken and terribly obsolete. Completely unreliable.  

Dec 5, 2013 

"Basically, they get away with violating the rules until the plant runs away from the staff and NRC!  We really got the national philosophy of ghost regulations and rules...  "translucent or barely visible wispy shape rules" that come in and out of reality depending on if they are convenient to profits and plant viability." 

Mike Mulligan Uncovers Wide Spread Problems with Safety Breaker in Nuclear Plants

Update 5/16

On the scheme of things, these large breaker aren't that complicated. Why can't they take these breakers into a lab and figure out what wrong in a short time. Mostly the bad vendor does the investigation. I believe there is huge corrupt collusion between the vendor and the plant. The vendor will "engineer" the investigation length in order to throw a favor to the plant. This will allow them to find replacements and fit into a outage. It is basically overriding the regulations. It facilitates increasingly tolerating degraded and defected parts in a nuclear plant. It creates a chilling inviroment in a control room. If you make it expensive to tolerate degraded in a plant with a immediate shutdown, it will send a message to the rest of the plants. The cheapest way out, replace degraded components when they first appear. These vendor are two steps away from NRC attention are notoriously corrupt. They make it so the licencee don't do the falsifying of documents risking their licence, the vendors faces the unlikely risk of the NRC wrath. I'd like these inventions done under the NRC's dime, then they would control the investigation.        

Power Reactor	Event Number: 51928
Facility: RIVER BEND Region: 4 State: LA Unit: [1] [ ] [ ] RX Type: [1] GE-6 NRC Notified By: ROB MELTON HQ OPS Officer: VINCE KLCO	Notification Date: 05/13/2016 Notification Time: 20:02 [ET] Event Date: 05/13/2016 Event Time: 12:00 [CDT] Last Update Date: 05/13/2016
Emergency Class: NON EMERGENCY 10 CFR Section: 50.72(b)(3)(v)(C) - POT UNCNTRL RAD REL	Person (Organization): VIVIAN CAMPBELL (R4DO)

Unit	SCRAM Code	RX CRIT	Initial PWR	Initial RX Mode	Current PWR	Current RX Mode
1	N	Y	100	Power Operation	100	Power Operation

Event Text

EXISTING DESIGN INADEQUACY COULD PREVENT STANDBY GAS TREATMENT SYSTEM OPERABLITY "At 1200 [CDT] May 13, 2016, while the plant was operating at 100% power, it was brought to the attention of the River Bend Station Main Control Room staff that an existing design inadequacy could prevent both trains of the Standby Gas Treatment System (GTS) from performing its design function. Under certain specific conditions, the installed Masterpact breakers may not close to allow energization of the filter train exhaust fans. A start signal (reactor level 2, drywell pressure 1.68 psid, annulus high radiation, annulus low flow) combined with a trip signal within a certain time differential, could result in a failure of the breakers to close. As a result of this condition, both Standby Gas Trains were declared inoperable, which required entry into LCO 3.6.4.3 Condition C (requires entering Mode 3 in 12 hours). Declaring both trains of Standby Gas Treatment System inoperable resulted in loss of the safety function since a system that has been declared inoperable is one in which the capability has degraded to the point where it cannot perform with reasonable expectation or reliability. "The Standby Gas Treatment System (GTS) limits release to the environment of radioisotopes, which may leak from the primary containment, ECCS systems, and other potential radioactive sources to the secondary containment under accident conditions. "At 1240 [CDT] May 13, 2016, one division of GTS, GTS 'A', was manually started from the Main Control Room. This action prevents the breaker failure mode, restored the operability of one train and restored the safety function of the GTS system. LCO 3.6.4.3 Condition A (restore Operability in 7 days) is currently entered for Standby Gas Train 'B'. During the 40 minutes of inoperability, both trains of Standby Gas remained available. At no time was the health or safety of the public impacted. "This condition is being reported in accordance with 10CFR50.72(b)(3)(v)(C) as an event that could have caused a loss of safety function to control the release of radioactive material. The Senior NRC Resident was notified."

Me on 5/13

"The utilities should be forced to assume all masterpact breakers are unsafe and immediately enter the appropriate tech spec LCO until masterpact breaker are eradicated from the plant."

Really, this is what is wrong in the industry. They have been deciding this since early 2115? This is NRC trickery, as letting them get away with it until replacements are on site. Why don't we see a slew of these reports all through the nation?  

Updated

This is a excerpt from a NRC allegation Department letter to me below. I didn't make a official allegation here, but have made many other allegations not related to the plant. I am very familiar with how to make a proper allegation. Just wanted a talk to the resident. The NRC made it a allegation without my permission.  

"On January 26, 2015, the NRC began the special inspection. This inspection was concluded on May 21. Similar issues to those listed by you were identified during this inspection. The results of this inspection will be documented in NRC Inspection Report 05000458/2015009. This inspection identified a number of observations, issues, and findings-with regard to the licensee's equipment, maintenance, and operations personnel performance. 

In addition to the above event, on March 9, 2015, the River Bend Station experienced another event, whereby the HVK chiller 1 C failed to start, followed by the subsequent loss of the control building ventilation system. This event and associated equipment failures revealed a much broader concern that has been ongoing with an identified master pact breaker deficiency related to the breaker's ability to open and close. This, along with the issues associated with the GE Magne Blast circuit breakers described above, calls into question the overall adequacy of the licensee's breaker maintenance program. These concerns resulted in a second special inspection, which began on March 30, 2015 and was completed on May 28. Again, similar concerns to those listed by you were identified during this inspection."

The NRC standard of safety in nuclear plants is you have to unattainable, triplicate and absolute proof a safety component is unsafe, while the utilities can use any old internet troll assertion to keep a plant up at power when unsafe. 

The NRC sent me a letter saying the River Bend Special inspection was initiated on my call to the Resident inspectors and they found similarly related problems with the masterpact breakers. Read the letter in the link below with how the NRC discribed my safety assertion. 

NRC: Proof I Instigated The 2014 Christmas River Bend plant Scram Special Inspection

The utilities should be forced to assume all masterpact breakers are unsafe and immediately enter the appropriate tech spec LCO until masterpact breaker are eradicated from the plant.

Brand new River Bend LER indicating identification of the masterpact breaker problem emerged from the Mike Mulligan River Bend special inspection. That is one hell of a LER title. 

LER 2016-005-00: Potential Loss of Safety Function of Onsite AC Sources and Operations Prohibited by Technical Specifications Due to Uncorrected Circuit Breaker Control Logic Design Causing Intermittent Failure to Close

I can make the case I got the River Bend NRC residents off their asses and they discovered a cascade of problems at the plant, one being the masterpact issue among other big problems. This thing

They found so much junk broken in the first special inspection, it  would have too long, they finished documenting the junk in the second special inspection.  

NRC Special Inspection 2015010 And Preliminary White Finding

with half ass breaker overhauls has been simmering in the industry for decades. Since my 2015 concern about having problems with controlling reactor vessel in scrams, this has unbelievably cascaded into into four special inspections within a year. Basically each with seperate components, but each with identical models of the other. Basically Entergy keeps the nuclear staff maliciously and intentionally in a "confused state" in order to enhance profits.  

Excerpts:  

PART 21 - INITIAL NOTIFICATION OF MASTERPACT BREAKER FAIL TO CLOSE

The following information was a licensee received facsimile;

"Pursuant to 10CFR 21.21(d)(3)(ii), AZZ/NLI is providing written notification of the identification of a potential defect or failure to comply.

"On the basis of our evaluation, it has been determined that there is sufficient information to determine if the subject condition is left uncorrected could potentially create a Substantial Safety Hazard or could create a Technical Specification Safety Limit violation as it relates to the subject plant applications. The plants will need to evaluate their application to determine if the identified condition could have an impact to the plant operation.  

"Possible 'failure to close' condition of Masterpact breakers NT and NW style, that are being used with specific logic schemes that are subjected to 'anti-pump' conditions during normal operation. These breakers have a higher susceptibility to not return to the ready to close position after the close signal has been removed.

"PSEG reported approximately 14 instances with different breakers in different cubicles where they initiated an electric close order, and the breakers failed to close. All of the 14 instances were in applications of being used to start an inductive load.

 "Plants which have been supplied the Masterpact circuit breakers. 

Did this come out of the River Bend Special inspection. I provoked the NRC into discovering this. OMG!!! 

"PSEG Hope Creek - Issue Identified for NW style
River Bend - Issue identified for NT style
Callaway - This issue has not been identified however, the potential should be evaluated.
St. Lucie - This issue has not been identified however. the potential should be evaluated.
Turkey Point - This issue has not been identified however, the potential should be evaluated.
Beaver Valley - This issue has not been identified however, the potential should be evaluated.
Davis Besse - This issue has not been identified however, the potential should be evaluated.
Three Mile Island - This issue has not been identified however, the potential should be evaluated.
Calvert Cliffs - This issue has not been identified however, the potential should be evaluated.
Hatch -This issue has not been identified however, the potential should be evaluated.
STP - This issue has not been identified however, the potential should be evaluated.
SONGS - This issue has not been identified however, the potential should be evaluated.
KHNPUlchin - This issue has not been identified however, the potential should be evaluated.
KHNPKor i- This issue has not been identified however, the potential should be evaluated.
Duke Oconee - This issue has not been identified however, the potential should be evaluated.
Duke McGuire - Non-safety (not supplied by NU), This issue has not been identified.

Junk Plant Susquehanna: Loss of Essential Loads and Then Scram?

That is amazing: No Automatic scram?

Power Reactor	Event Number: 51925
Facility: SUSQUEHANNA Region: 1 State: PA Unit: [ ] [2] [ ] RX Type: [1] GE-4,[2] GE-4 NRC Notified By: CARL YOUNG HQ OPS Officer: HOWIE CROUCH	Notification Date: 05/13/2016 Notification Time: 05:00 [ET] Event Date: 05/13/2016 Event Time: 01:10 [EDT] Last Update Date: 05/13/2016
Emergency Class: NON EMERGENCY 10 CFR Section: 50.72(b)(2)(iv)(B) - RPS ACTUATION - CRITICAL 50.72(b)(3)(v)(C) - POT UNCNTRL RAD REL 50.72(b)(2)(iv)(A) - ECCS INJECTION	Person (Organization): ART BURRITT (R1DO) SCOTT MORRIS (NRR)

Unit	SCRAM Code	RX CRIT	Initial PWR	Initial RX Mode	Current PWR	Current RX Mode
2	M/R	Y	100	Power Operation	0	Hot Shutdown

Event Text

MANUAL REACTOR SCRAM DUE AFTER LOSS OF AN ESSENTIAL MOTOR CONTROL CENTER "At approximately 0110 hours [EDT] on May 13, 2016, Susquehanna Steam Electric Station Unit Two reactor was manually scrammed by plant operators due to a sustained loss of AC power to essential plant loads. Power to MCC 2B246 was lost at 2355 on May 12, 2016, resulting in a loss of Drywell cooling. Drywell pressure increased to 1.3 psig when operators placed the mode switch to the shutdown position to manually SCRAM the reactor. All rods inserted as expected. Reactor water level lowered to -27 inches and was immediately restored by normal feedwater level control. Level 3 (+13 inch) PCIS isolations occurred, along with an initiation of the RCIC system (-30 inches). Once adequate level was verified, RCIC was overridden. Pressure was controlled with turbine bypass valves, and subsequently main steam line drains. All safety systems functioned as expected. "The power loss also tripped Reactor Building HVAC, causing a loss of secondary containment differential pressure resulting in a loss of safety function. "Due to the loss of drywell cooling, high drywell pressure actuations and a second reactor SCRAM signal, this signal was automatic, occurred at 0314 hours. HPCI [which automatically initiated on high drywell pressure] was subsequently overridden and declared inoperable, resulting in a loss of safety function. [HPCI did not inject into the vessel]. "The reactor is currently stable in Mode 3. Initial reports from the field indicate a phase to phase fault on the MCC 2B246 bus bars." The licensee has notified the NRC Resident Inspector and will be issuing a press release.

Junk plant Fort Calhoun Going To Shut Down

All that recovery money being wasted. It is very costly having on

"The nuclear plant came back online in December 2013 after a fire and Missouri River flooding forced a two-and-a-half year outage. A February 2015 report from ratings agency Standard & Poor's tallied the cost of the outage at $341 million."

board two management structures. I bet OPPD could see an intensification of future maintenance expenses in front of them based on a obsolete plant and with a poor replacement parts stream. 

It is obvious now, all the degraded equipment and safety issues revolved around secret pre flooding OPPD budget and suicidal prioritization issues at the plant, to the NRC's peril. The low grid prices are putting the NRC under tremendous and historic pressures. I am telling you people, something is going to snap.  OPPD was secretly starving funding to the plant until failure, then a burst of big expenses after 2011 until the shutdown decision. The war on dead-ender prioritization of issues continues in the rest of the plants.  
   
Mark my words, Wolf Creek is next, or an intensification of NRC attention will get them to drop out.

The moral of the story behind any plants decline, everyone knowingly keeps increasing secrets in what is utimately causing the decline until the bitter end.  

OPPD CEO recommends closing Fort Calhoun nuclear power plant

Published 6:13 PM CDT May 12, 2016

A lot of big numbers were presented from the management team after OPPD executives confirmed the decision. OPPD could save $700 million to $900 million over the next 20 years if it closes the nuclear plant, and there would be no potential rate increases until 2021.

Board members now have a lot to think about after getting the official recommendation.

"You just can't keep losing money," OPPD board member Tom Barrett said. "You have to say enough is enough and you've got to stop the loss. That's the cold, hard facts of this business."

While OPPD's nuclear reactor pumps out power, it's also running up millions of dollars in red ink.

"The facts are, unfortunately, that the market is just not there right now," OPPD board member Tim Gay said.

"It's just not viable. It's just not economically viable," OPPD board member John Green said.

While the plant no longer makes financial sense to district executives, employees' hard work has not gone unnoticed. After a fire and flood in 2011, there was around-the-clock work to get the plant back online. CEO Tim Burke got emotional speaking about it.

"We've asked them to do so many things, and they've been both-feet-in every time we've asked them," Burke said.

The utility's leader also made a point to say if Fort Calhoun comes offline, it will take time.

OPPD isn't planning any immediate layoffs but wants decommissioning to start by the end of the year.

"Eventually it was going to happen anyway, you know, but it's just too bad it has to be now," OPPD board member Fred Ulrich said.

The board won't vote to pull the plug until its June meeting.

Not many nukes can survive on a "$30 per mega watt hours" and this period of budget starvation and dead-ender prioritization of safety issues is very dangerous on the nation wide level.  

***"In general, without knowing the specific cost of the power plant, I can tell you it's about $50 a mega watt hour [to produce nuclear energy]," said Mike Matheson, president of Grain Belt Energy in Lincoln.

Matheson is a nuclear power veteran, spending more than a decade at Nebraska Public Power District's Cooper Station.
He said current market prices to purchase electricity are about $20 per megawatt hour, a figure confirmed by OPPD's CEO Tim Burke

Matheson said it would not surprise him that OPPD would float the possibility of shuttering Fort Calhoun to meet that goal

To date, OPPD paid more than $80 million to Exelon Corp. to manage Fort Calhoun Station. A 20-year contract with the Chicago-based energy giant was part of an effort to reopen the nuclear plant after a fire and the 2011 Missouri River flood.

*After power production ceased in April 2011 and regulators ratcheted up oversight, OPPD in 2012 entered the 20-year, $400 million contract with Exelon; that Chicago-based nuclear company is the largest of its kind in the United States and now runs the Fort Calhoun plant for OPPD, which continues to own the plant and has its own staff connected to the plant’s operation

Junk Plant Fermi New Inspection Report: Dissolution With 11 Violations

I explained it on Feb 29, 2016 in a amazingly accurate post, in the early reports about this terribly chaotic organization. The best quotes: Junk Plant Fermi Can't File A Clean Event Report. 

"This is the second time (2/02/1016) the turbine bypass flings open?"  

"Again not reporting accurate (and timely) event reports."

"It starts out as a leak in the Turbine Building Closed Cooling. So this event occurred on Sept 13 and it takes them all this time to fix the event report. Sounds like the NRC provoking Fermi to fix inaccurate" 

In the below, they should fire the training department top manager, the training department manager of licenced operators and the top operations manager of licenced operators. Or at least to publicly demote them. Get somebody else in there to get the job done. 

The NRC is increasing finding simulator fidelity issues in serous plant transients and trips, such as Pilgrim and River Bend. The NRC has a pattern of not being about to detect simulator fidelity issues in training and simulator inspections before it shows as adventures in plant accidents. Many of the residents just don't have the expertise or time to catch it on their own. The NRC risk calculations, and thus penalty, isn't big enough to make the industry make their training simulators identical to the plants. Mostly big dog licencing on shift manage get these plum jobs in training. Anything to get off shift work. These guys have been on shift for decades, they are titans and untouchable to the rest of the licencing operators (Huge kiss asses all their lives subverting the professional licensed operator profession) The licencees operators to the one are extremely intelligent. They know when the simulator doesn't model the plant. They secretly kid between themselves with the traps on simulator un-fidelity. It is not that it mysteriously pops out of nowhere...its everyone knows it except the NRC and senior corporate managers and executives. It is an increasing culture of secrecy plant wide you should worry about. It managers burying the bad news to not fix expensive problems. It is a sense of intimidation by the bad dog training managers and operations managers, don't rock the boat. Its not the risk of few operators doing the wrong activities leading to highly improbable meltdown. It symbolizes a much wider global risk effecting all of organization everywhere with insider secrets and severe safety intimidation. It is a wide spread and global severe safety culture problem effecting everything the organization does. It the big dog managers and executives intimidating the little fish. How does anyone now know the actual real condition of the facility and it organization. It is when crazy stupid events and equipment  problems just seemingly pops up out of nowhere. Really crazy stupid unexplained stuff popping up seemingly out of nowhere. Why didn't the operator get the NRC to fix their simulator?         

"So they got a scram on cycling SRVs valves twice. It indicates problems with training"

It is rule, procedure, plant licencing, training, NRC reporting violations and preventable equipment problems on a massive level. It reminds me of Pilgrim in 2013. The NRC seems to be hiding the extent of the problem. 

May 9, 2016

SUBJECT: FERMI NUCLEAR POWER PLANT, UNIT 2—NRC INTEGRATED INSPECTION REPORT 05000341/2016001

The NRC inspectors documented seven findings of very low safety significance (Green) in this report. Six of these findings involved violations of NRC requirements. In addition, the inspectors identified three performance deficiencies that were associated with Severity Level IV violations of NRC requirements evaluated through the traditional enforcement process. Two licensee-identified violations are also documented in this report. One of these licensee identified violations was determined to be of very low safety significance and the other one was evaluated through the traditional enforcement process as Severity Level IV. The NRC is treating each of these violations as Non-Cited Violations (NCVs) consistent with Section 2.3.2.a of the NRC Enforcement Policy.

1) Green. A finding of very low safety significance with an associated NCV of 10 CFR 55.46(c), “Plant-Referenced Simulators,” was self-revealed. The licensee failed to ensure the plant-referenced simulator demonstrated expected plant response to normal, transient, and accident conditions to which the simulator was designed to respond. Specifically, the licensee failed to maintain the simulator consistent with actual plant response.

The performance deficiency was of more than minor safety significance because it adversely affected the human performance attribute of the Initiating Events cornerstone and affected the cornerstone objective of limiting the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations.

2) Green. A finding of very low safety significance with an associated NCV of 10 CFR 50.65, "Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," was self-revealed when the failure of a tube inside the east turbine building closed cooling water (TBCCW) heat exchanger caused a trip of the TBCCW pumps and a manual reactor scram due to the loss of all TBCCW. The heat exchanger tube failure occurred, in part, due to the licensee’s failure to incorporate industry operating experience in order to perform adequate preventive maintenance on the component. 

The performance deficiency was of more than minor safety significance because it was associated with the equipment performance attribute of the Initiating Events cornerstone and adversely affected the cornerstone objective of limiting the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. 

3) Green. A finding of very low safety significance with an associated NCV of Technical Specification (TS) 5.4, “Procedures,” was self-revealed when a valid automatic reactor scram signal and isolation signal for multiple primary containment isolation valves was actuated. A reactor operator, who was maintaining RPV water level and reactor pressure following a plant scram, did not initiate reactor core isolation cooling (RCIC) system flow in time to maintain level above the Level 3 reactor protection system actuation setpoint. 

The performance deficiency was of more than minor safety significance because it was associated with the Human Performance attribute of the Initiating Events cornerstone and adversely affected the cornerstone objective of limiting the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. 

Cornerstone: Mitigating Systems

4) Green. The inspectors identified a finding of very low safety significance with an associated NCV of TS 5.4, “Procedures.” Specifically, the licensee failed to enter TS 3.3.1.1, Condition C when the high pressure stop valve (HPSV) closure and high pressure control valve (HPCV) fast closure reactor protection system (RPS) trip functions became inoperable while the main turbine bypass valves cycled open during a plant transient on January 6, 2016.

The performance deficiency was of more than minor safety significance because a failure to correctly implement TS Limiting Condition for Operation (LCO) requirements has the potential to lead to a more significant safety concern if left uncorrected. Specifically, a failure to declare an LCO not met, enter the applicable condition(s), and follow the applicable actions could reasonably result in operations outside of established safety margins or analyses.

Green. The inspectors identified a finding of very low safety significance with an associated NCV of 10 CFR 50, Appendix B, Criterion III, “Design Control.” Specifically, the licensee failed to demonstrate the residual heat removal heating, ventilation, and air conditioning (RHRHVAC) system would be able to maintain a required minimum temperature of 40 degrees Fahrenheit (°F) for the emergency diesel generator (EDG) fuel oil storage tank (FOST) rooms under minimum design conditions, potentially rendering the EDGs inoperable. 

The performance deficiency was of more than minor safety significance because a failure to correctly incorporate design requirements into plant procedures has the potential to lead to a more significant safety concern if left uncorrected. Specifically, since the EDG FOST rooms were unmonitored and a subsequent calculation demonstrated the RHRHVAC system was not able to maintain the minimum required temperature in the rooms as described in the design basis, the EDGs could have been rendered inoperable without the licensee’s knowledge. 

Cornerstone: Barrier Integrity 

5) Green. The inspectors identified a finding of very low safety significance with an associated NCV of 10 CFR 50, Appendix B, Criteria V, “Instructions, Procedures, and Drawings.” Specifically, the licensee failed to include appropriate quantitative or qualitative acceptance criteria in its surveillance test procedures for fulfilling the monthly Technical Specification surveillance requirement to demonstrate operability of the standby gas treatment system (SGTS). 

The performance deficiency was of more than minor safety significance because it was associated with the procedure quality attribute for the control room and auxiliary building and adversely affected the Barrier Integrity cornerstone objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. Specifically, by not providing appropriate acceptance criteria by which the operability of the SGTS trains could be assessed, the ability of the SGTS to collect and treat the design leakage of radionuclides from the primary containment to the secondary containment during an accident could not be assured. The finding was determined to be of very low safety significance because it involved only a degradation of the radiological barrier function provided by the SGTS. The inspectors concluded that because this condition has existed for greater than three years, this issue would not be reflective of current licensee performance and no cross-cutting aspect was identified.

Other Findings

6) Severity Level IV. The inspectors identified a Severity Level IV NCV of the 10 CFR 50.72(a)(1), “Immediate Notification Requirements for Operating Nuclear Power Reactors,” and 10 CFR 50.73(a)(1), “Licensee Event Report [LER] System.” Specifically, the licensee failed to make a required 8-hour non-emergency notification call to the NRC Operations Center after discovery of a condition that could have prevented the fulfillment of the safety function to shut down the reactor on February 21, 2015, and on January 6, 2016 (two separate occurrences). In addition, the licensee failed to submit a required LER within 60 days after discovery of the event on February 21, 2015. Subsequently, the licensee made an 8-hour notification call on February 25, 2016 to the NRC Operations Center via the Emergency Notification System to report the two events (Event Notices 51755 and 51756). On March 2, 2016, the licensee updated Event Notices 51755 and 51756 to include an additional reporting criterion. The licensee submitted LER 05000341/2015-008-00, “Turbine Stop Valve Closure and Turbine Control Valve Fast Closure Reactor Protection System Functions Considered Inoperable Due to Open Turbine Bypass Valve,” on March 29, 2016, to report the February 2015 event. The licensee entered this issue into its corrective action program to evaluate the cause for its failure to satisfy the reporting requirements and to identify appropriate corrective actions.

7) Severity Level IV. The inspectors identified a Severity Level IV NCV of 10 CFR 50.73(a)(1), “Licensee Event Report [LER] System,” for the licensee’s failure to submit a required LER within 60 days after the discovery of an event on July 28, 2015, that was reportable in accordance with 10 CFR 50.73(a)(2)(i)(B) as a condition prohibited by the plant’s Technical Specifications. The condition involved the licensee’s failure to complete required actions for an inoperable ultimate heat sink reservoir and for both emergency diesel generators in one division inoperable within the allowed completion times. The licensee subsequently submitted LER 05000341/2015-009-00, “Condition Prohibited by Technical Specification Due to Missed Entry into LCO [Limiting Condition for Operation] Condition,” on March 31, 2016, to report the event. The licensee entered this issue into its corrective action program to evaluate the cause for its failure to satisfy the reporting requirements and to identify appropriate corrective actions. 

8) Green. The inspectors identified a finding of very low safety significance for the licensee’s failure to implement its procedure standards when performing an apparent cause evaluation for a condition adverse to quality. Specifically, the inspectors determined that the licensee did not adequately develop the direct and apparent cause of the problem in the evaluation, did not correctly assess the impact of relevant internal and external operating experience, and did not identify appropriate corrective actions to address management behaviors that resulted in the problem. No violation of regulatory requirements was identified because the scope of issues evaluated by the licensee’s procedure standards for performing the apparent cause evaluation was not limited to safety-related structures, systems, and components. The performance deficiency was of more than minor safety significance because it would have the potential to lead to a more significant safety concern if left uncorrected. Specifically, the failure to adequately perform apparent cause evaluations could result in ineffective corrective actions for conditions adverse to quality and safety. The finding was determined to be of very low safety significance based on a qualitative evaluation of the potential consequences of the performance issue. The inspectors considered the three examples evaluated in the licensee’s apparent cause evaluation and found the significance of each performance issue was not greater than very low safety significance. The inspectors concluded this finding affected the cross-cutting aspect of evaluation in the problem identification and resolution area. The licensee did not adequately evaluate the problem to ensure corrective actions would address the causes and extent of conditions commensurate with safety significance. Specifically, the apparent cause evaluation failed to identify and understand the basis for management decisions that contributed to the problem; therefore, corrective actions to address appropriate changes in management behaviors were not developed [IMC 0310, P.2]. (Section 4OA2.2) 

9) Severity Level IV. The inspectors identified a Severity Level IV NCV of 10 CFR 50.72(a)(1), “Immediate Notification Requirements for Operating Nuclear Power Reactors,” and 10 CFR 50.73(a)(1), “Licensee Event Report [LER] System.” Specifically, the licensee failed to make a required 8-hour non-emergency notification call to the NRC Operations Center and also failed to submit a required within 60 days after discovery of a condition that resulted in the valid actuation of containment isolation signals affecting containment isolation valves in more than one system on September 13, 2015, and September 14, 2015 (two separate occurrences). Subsequently, the licensee made an 8-hour notification call on February 27, 2016 to the NRC Operations Center via the Emergency Notification System to report the events (Event Notice 51391, third update). The licensee entered this issue into its corrective action program to evaluate the cause for its failure to satisfy the reporting requirements and to identify appropriate corrective actions. 

Licensee-Identified Violations

10) Technical Specification 3.7.2, “Emergency Equipment Cooling Water (EECW) /Emergency Equipment Service Water (EESW) System and Ultimate Heat Sink (UHS),” Required Actions, Note 1, states: “Enter applicable Conditions and Required Actions of LCO 3.8.1, ‘AC [Alternating Current] Sources – Operating,’ for diesel generators made inoperable by UHS.” Technical Specification 3.8.1, Condition A is required when one EDG is inoperable and Condition B is required when both EDGs in one division are inoperable.

Technical Specification 3.8.1, Required Actions A.1 and B.1, state: “Perform SR 3.8.1.1 for operable offsite circuit(s) within 1 hour and once per 8 hours thereafter,” and TS 3.8.1, Required Action A.3, states: “Verify the status of CTG 11- 1 once per 8 hours.” Contrary to the above, on July 28, 2015, with the Division 2 UHS reservoir inoperable, the licensee failed to enter the applicable conditions and required actions of TS 3.7.2 and subsequently, failed to enter TS 3.8.1 for both Division 2 EDGs made inoperable by an inoperable UHS reservoir. Consequently, with both EDGs in one division inoperable, the licensee failed to complete TS 3.8.1, Required Actions A.1 and B.1, to perform SR 3.8.1.1 for operable offsite circuits within 1 hour and once per 8 hours thereafter, and also failed to complete TS 3.8.1, Required Action A.3, to verify the status of CTG 11-1 once per 8 hours. In addition, with the required actions and associated completion times of Conditions A and B not met, the licensee failed to complete TS 3.8.1, Required Action G, to be in Mode 3 within 12 hours. The failure to complete these TS required actions is a violation of TS 3.8.1.

11) Title 10 of the CFR, Paragraph 50.72(a)(1)(ii) requires, in part, that the licensee shall notify the NRC Operations Center via the Emergency Notification System of those non-emergency events specified in Paragraph (b) that occurred within three years of the date of discovery and 10 CFR 50.72(b)(3) requires, in part, that the licensee shall notify the NRC as soon as practical and in all cases within eight hours of the occurrence of any of the applicable conditions. Moreover, 10 CFR 50.72(b)(3)(iv)(A) requires, in part, that the licensee report any event or condition that results in valid actuation of any of the systems listed in Paragraph (b)(3)(iv)(B) and 10 CFR 50.72(b)(3)(iv)(B)(2) lists general containment isolation signals affecting containment isolation valves in more than one system or multiple MSIVs. 

In addition, 10 CFR 50.73(a)(1) requires, in part, that the licensee submit an LER for any event of the type described in this paragraph within 60 days after the discovery of the event and 10 CFR 50.73(a)(2)(iv)(A) requires, in part, that the licensee report any event or condition that resulted in manual or automatic actuation of any of the systems listed in Paragraph (a)(2)(iv)(B). Paragraph (a)(2)(iv)(B)(2) in 10 CFR 50.73 lists general containment isolation signals affecting containment isolation valves in more than one system or multiple MSIVs. 

Contrary to the above: 

1. The licensee failed to notify the NRC Operations Center via the Emergency Notification System of a non-emergency event specified in Paragraph (b) within eight hours of an event on September 14, 2015. The event involved the valid manual and automatic actuation of the primary containment isolation logic for multiple MSIVs. 

2. The licensee failed to submit a required LER within 60 days after discovery of an event on September 14, 2015. The event involved the valid manual and automatic actuation of the primary containment isolation logic for multiple MSIVs. Violations of 10 CFR 50.72 and 10 CFR 50.73 are  is positioned using the traditional enforcement process because they are considered to be violations that potentially impede or impact the regulatory process. In accordance with Section 6.9.d.9 of the NRC Enforcement Policy, this violation was categorized as Severity Level IV because the licensee failed to make a report to the NRC as required by 10 CFR 50.72(a)(1)(ii) and 10 CFR 50.73(a)(1). The licensee entered this violation into its CAP as CARD 16-20564.