Thursday, November 09, 2017

NRC Official Allegation To Me and Required Acknowledgement: Vogtle and Westinghouse


(Works in progress)

Hmm, Washington's Allegation people, not Region 1 or 2 Allegation people. They are paying attention to me. 

So what is the political scene? Huge political shift seen out of this recent election. Everyone is going to vote mid terms "any one but Trump". The pols are worrying about a huge shift in the senate and house. We have entered a completely new political arena.

What about our southern break away rebel territories? You know our south. Once the money stopped flowing to the Summer, all the rats began jumping ship and telling their tales. The Summer plant only a few months are was basically a honey pot for the elites of South Carolina, now whistleblowers have come out telling us how chaotic the site was. Disclosing after the money stopped is really not whistleblowing. Whistleblowing are disclosures made when the spigot is going full bore. So now the Summer Plant has a host of state and federal investigation ongoing. The whole system is riddled with corruption. 
So what way do you think the Georgia Public Service Board is heading. The Commissioners are all politicians and get elected. They are effectively the great southern good old ultra conservative right wing boys. They are indebted to the utilities. The Southern Company,  like all utilities, a astute and wealthy political player. These guys are masters of the game.

I think we will see a dramatic change with the PSB. They see the historic anti Trump tsunami  approaching them in the mid terms. It is going to be a long term change. They know the documentation is shaky at Summer. They worry there is big secrets buried on the Vogtle grounds, just ready to burst out like Summer on a whim. The PSB is worried about getting subpoenas, just like about anyone who works on the Vogtle plant.

I am sure the NRC understands this.

I would expect the PSB will pay it safe, they will take Vogtle 3 & 4 off the rate base.      

Wednesday, November 08, 2017

Exelon's Merchant Subsidiary Files For Bankrupcy


Market conditions must be bad?
Exelon's Texas merchant subsidiary files for bankruptcy
By
Published
Nov. 7, 2017
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Dive Brief:
Exelon Corp. announced this morning that its Texas merchant power subsidiary ExGen Texas Power (EGTP) Holdings LLC and ExGen Texas Power LLC filed for Chapter 11 bankruptcy, with an eye towards reducing debt at the companies.
News stories earlier this year cited anonymous sources saying Exelon had brought an adviser on board to help it deal with mounting debt at the power subsidiary. The company reportedly selected PJT Partners Inc. to help address $650 million in debt.
EGTP's Board of Directors will go forward with a two-part plan for the company, including a negotiated agreement with lenders that would allow Exelon Generation to continue to own and operate the Handley Generating Station in exchange for a $60 million payment to the lenders. 
Dive Insight:
Prior to the announcement, ExGen Texas Power owned five generating facilities in the Lone Star state, but the bankruptcy agreement will change that. In the second part of the company's plan, lenders agreed to exchange the debt they currently hold in EGTP’s other four plants for equity in the plants, effectively taking ownership of all but Handley.
In a statement, the company said Exelon Generation "remains committed to working with all stakeholders to ensure the best outcome for our employees, customers, communities and shareholders.” The bankruptcy filings "help to facilitate the planned transactions and provide additional tools to reduce the amount of debt the plants would otherwise take forward, thereby maximizing their opportunities for long-term success."
Exelon blamed the financial woes on "historically low power prices within Texas" that created "challenging market conditions for all power generators, including the five natural gas-fired EGTP plants." 

UCS :Junk Plant Grand Gulf 

He knows how I feel about Grand Gulf. 
Dave Lochbaum, director, Nuclear Safety Project | November 8, 2017, 6:00 am ES

This post is a part of a series on Near Misses at U.S. Nuclear Power Plants
The Nuclear Regulatory Commission (NRC) reacted to a trio of miscues at the Grand Gulf nuclear plant in Mississippi by sending a special inspection team to investigate. While none of the events had adverse nuclear safety consequences, the NRC team identified significantly poor performance by the operators in all three. The recurring performance shortfalls instill little confidence that the operators would perform successfully in event of a design basis or beyond design basis accident…

Junk Plant Fitzparick: Fuel Failures

update Nov 10

So why has Fitz been down to 75% power since the fuel leak down power last weekend? It has been down for 5 or 6 days? It is highly abnormal!!!

So what changed? They were heading to a near death experience, then Energy sold the plant to Exelon.  I don't remember them having fuel damage problems before. Outage in Jan 2017.

Fretting... small metal parts from the outage circulating in the coolant.

Three showing up at the same time, abnormal. Are they in the same area of the core?

Did they change the fuel supplier?  
Radiation from damaged fuel rods leads Oswego nuke plant to power down
Updated Nov 7, 4:14 PM; Posted Nov 7, 3:31 PM

The FitzPatrick nuclear power plant in Scriba, Oswego County.(NRC)

By Douglass Dowty

ddowty@syracuse.com,

syracuse.com

Oswego, NY -- Officials at the FitzPatrick Nuclear Power Plant near Oswego are investigating why fuel rods in the reactor's core are leaking radiation, according to the federal government.

It's a not considered an emergency -- only three of the plant's roughly 33,500 fuel rods are leaking -- but it could spread contaminated water to other parts of the plant, said U.S. Nuclear Regulatory Commission spokesman Neil Sheehan.

So FitzPatrick's parent, Exelon Corp., powered down the facility over the past few days to isolate the damaged fuel rods, Sheehan said.

The plant was down to 58 percent capacity over the weekend before ramping up to 82 percent capacity today. It's on the way back to full capacity, Sheehan said.

An Exelon spokeswoman called it a minor problem.

"Operators have suppressed a minor defect in a fuel bundle using control rods, which
This is going to be a very costly event. It is going to make the core and all their components more costly with contamination. It slows down all the jobs with costly radiation precautions. Depending the type of leak, it could get much more costly with a much bigger leak. Preparing for the permanent shutdown many years prior too, they might have shifted the core flux so they could use up as much uranium as possible upon last shutdown. Now they had to rearrange the core back to normal operation. It is a very complex operation not normally done. There just might be a error in that.   
will allow for reliable operation until the station's next refueling outage when the bundle can be replaced," said Tammy Holden, the company spokeswoman.

The NRC said that the leakage doesn't pose any health risk for the community: the water in contact with the damaged fuel rods is part of a closed system with filters that remove dangerous levels of contamination.

But Sheehan called it an "anomaly" that the company would need to address.

The rods themselves are 12 feet long and about the width of an index finger, Sheehan said.

FitzPatrick, like its Nine Mile Point neighbors, uses a nuclear reaction to heat up water, which then powers a turbine. It's the heated water that is prone to increased contamination from the damaged fuel rods.

But that water is scrubbed and sent back to the reactor core, not released into the environment, Sheehan said.

Exelon is in the process of isolating the leaking rods, which will then be taken out of service and replaced at the next refueling, which happens every 18 months to 2 years, Sheehan said.

Tuesday, November 07, 2017

Junk Plant Grand Gulf: Can't Make Any Money With This Dog? 

Update Non 8

93% last night.

***They have been down  to 99% for the last few days. Not enough to make a post about. But on the second day of 99% power I knew something was up.

Huge down power to 58% today. The other region IV Entergy plants have been behaving well in the last few months.

Voglte Non Professional Engineers.

The NRC was focused on pumping me about who gave me the inside tip. There just wasn't much she gave me. You here is me saying now is this enough information to open a investigation.

Michael Mulligan <steamshovel2002@yahoo.com>
To:allegation@nrc.gov
‎Nov‎ ‎6 at ‎11‎:‎06‎ ‎AM

I apologized because I was a still upset over the Vogtle and Summer plants last time we spoke. I have been working on this a little with the Atlanta Journal Constitution.  You know, getting the word out.
What I can see, the NRC was not proactive by assuming Vogtle blue prints not approved by professional engineers.” A high quality inference  should have been enough to start a investigation.!!!
“One of the items on the PSC agenda will be documents that have come to light that show that Southern affiliate Georgia Power signed off on the blueprints for the reactors that were not approved by professional engineers.”


So I got a call from two NRC officials following me up on my compliant about non professional engineering. I am trying to throw the AJC a bone trying to get them to ask question. I would call the AJC a captured news paper to the new build.

But pretty quickly after I sent this news about non professional engineers at Vogle, the PSC disclosed there are investing my issues.

Michael Mulligan <steamshovel2002@yahoo.com>
To:businessnews@ajc.com

Nov‎ ‎1 at ‎9‎:‎52‎ ‎AM
Dear Sir,

“Stamped for failure: Westinghouse and SCANA used unlicensed workers to design abandoned S.C. nuclear reactors”

"In other SCANA news, The National Society of Professional Engineers has called on the Nuclear Regulatory Commission to investigate the V.C. Summer nuclear project, The Post and Courier reported. The association called for the federal agency to look into the failed construction after a revelation that Westinghouse, with complicity from SCANA, used unlicensed engineers to authorize design plans for the reactors. “Internal published documents also allege a deliberate attempt by Westinghouse attorneys to narrowly interpret South Carolina professional engineering statutes to evade generally accepted design and construction practices,” said Tom Roberts, president of the National Society of Professional Engineers."  

There is a ongoing NRC investigation at Vogtle to see if they used unlicenced workers and engineers like Summer. I made the complaint as soon as the Summer issue popped up. I got a tip from a Vogtle employee. So far the NRC admitted to me they used state non licensed engineers on the secondary systems. It is all going to key on state and NRC regulations...the expectations of the public???

Mike Mulligan
Hinsdale, NH

16032094206

Is The Same Going On In Vogtle, as in VC Summer?

Update: 

I was right...non professional engineers at Vogtle. They just admitting it and back a few days ago Allegations gave me call asking me for more information. The southern co stock price seemed to tanked on the news yesterday.  


Republished from 9/26

Update The gist of my complaint. 
 Sorry, it seems like my spell checker wasn’t working when I wrote it. Please use this version. All I did was correct the spelling
Mike Mulligan <steamshovel2002@gmail.com>
3:21 PM (5 hours ago)
https://mail.google.com/mail/u/0/images/cleardot.gif
https://mail.google.com/mail/u/0/images/cleardot.gif
https://mail.google.com/mail/u/0/images/cleardot.gif
to OPA, R1ALLEGATION, R2Allegations
https://mail.google.com/mail/u/0/images/cleardot.gif
The addition NRC email address, OPA Resource, is me trying to get the NRC blog to write up a article concerning Summer and Vogtle's non licensed engineers. 
“Is The Same Going On In Vogtle, as in VC Summer?’
We need a short description with what occurred at the Summer site on the non licensed engineer signoffs. We also need a comparison between Summer and Vogtle sites over the non licensed signatures. Are they similar, or is one worst than the other.
Request the Vogtle 3 and 4 site be shutdown until the non licensed engineer issue is straighten out. Does Vogtle 1 and 2 have the same problem?
Mike Mulligan  
Hinsdale, NH
Update
Melanie,

CC’ed on this email is Mike Mulligan, a concerned citizen who called the NRC Allegation hotline today. I have included him on this email so he can respond with a link to a newspaper article that is relevant to his concern.

Mr. Mulligan stated that he received a call from an Engineer who works at Vogtle, who claimed that they have the same problem as what is going on at  VC Summer: Non-licensed engineers are signing off on safety-related diagrams/paperwork that should be signed off by licensed engineers.

In addition to the email address listed on cc, you can contact Mr. Mulligan at (603) 336-8320.

If you need anything else from me do not hesitate to reach out.

Sincerely,

Nicole Warnek
Sr. Allegation Coordinator
610-337-5222 (Region I Safety Hotline)
800-432-1156 x5222 (Hotline, Toll Free)

So why isn't this going on in the Vogtle New build? I made a Allegation complaint to region II. I got a call from a from a Vogtle engineer saying the same was going on in his plant.
Sep 24, 2017 Updated Sep 25, 2017
COLUMBIA — Westinghouse and other contractors used unlicensed workers to design parts of two nuclear reactors in South Carolina, a potentially criminal shortcut that raises fresh questions about why the multibillion-dollar energy project failed. 
Documents obtained by The Post and Courier show construction drawings for the unfinished reactors were used at V.C. Summer without having them vetted and approved by professional engineers. 
In South Carolina and most states, every drawing for a large building project demands the stamp and signature of a licensed engineer — especially when that construction affects the public’s health and safety. Not following that law can lead to criminal penalties. 
But as the nuclear expansion got underway north of Columbia, neither state nor federal officials were told that unlicensed workers were crafting blueprints and conducting complex engineering calculations. This left professional engineers questioning the entire construction process that wasted $9 billion before it was cancelled in July.
The practice contributed to thousands of design revisions, construction setbacks, schedule changes and the ultimate demise of the reactors, those engineers said. 
“You literally can’t make up the errors that were propagated in this thing," said one engineer from V.C. Summer, who asked not to be named for fear of retribution. "I’ve never seen anything like this in my life. It was beyond comprehension. They enshrined incompetence.”
The nation turned its attention to South Carolina as Westinghouse and two of the state's largest utilities attempted to complete the first reactors built in the United States in decades. The endeavor promised to usher in a new age of nuclear power.
Instead, the project became a crater of debt that left electric customers on the hook for a squandered investment larger than the state's $8 billion annual budget.
Two legislative committees, South Carolina's attorney general and federal authorities have launched investigations into the failed project. 
It remains unclear exactly who was producing the unlicensed designs that led to problems, what education they had, where they were from or what their professional backgrounds were. 
But if you’re building a potentially dangerous nuclear reactor, V.C. Summer engineers argued, you should have certified professionals designing it — people willing to stand by the drawings they attach their name to. 
High stakes
It may not be well known outside the industry, but the licensing of engineers is a long-held and widespread practice that has a direct, if often unrealized, impact on everyone’s lives.
Roads, office buildings and new manufacturing facilities — professional engineers are required to oversee and sign off on drawings for nearly every large construction project in South Carolina. It protects the public and ensures people get what they pay for.
You want competent people designing the bridges you drive over, the dams located above your home and the nuclear plants in your backyard.
Texas’s engineering law was passed in 1937 after 295 students and teachers were killed at a school by a natural gas explosion caused by a faulty gas connection.
“The stakes are high,” said Arthur Schwartz, the deputy executive director and general counsel for the National Society of Professional Engineers. "That’s what engineers do. They’re responsible for systems and processes that the public relies on and probably takes for granted.”
A college degree doesn’t make someone a licensed engineer. It takes hours of rigorous testing and years of work under the guidance of experienced people before anyone can call themselves a “professional engineer.”
The new Westinghouse reactors offered a huge opportunity for professional civil, mechanical, electrical and nuclear engineers in the United States.
It was their chance to take part in something that hasn’t been accomplished in roughly three decades. It was an opening to showcase their abilities on a project intended to rebuild the country’s nuclear workforce.
In the years leading up to construction of four Westinghouse nuclear reactors in South Carolina and neighboring Georgia, executives with the 131-year-old company touted the safety features of the new AP1000 design. They celebrated the reactors’ unique modular construction. They promised it would eliminate schedule delays and budget overruns.
But designing and engineering a new nuclear power plant is a huge undertaking.
SCANA, the majority owner of the two South Carolina reactors, had convinced politicians and state utility regulators of the merits of nuclear power by the beginning of 2009. Westinghouse had cleared most of its high-level design for the reactors with federal nuclear regulators.
The details of what bolts needed to be installed, where electrical wires would run and how pipes would be configured, however, had yet to be worked out. It meant tens of thousands of drawings and blueprints needed to be designed, reviewed and approved before they went into the hands of ironworkers, electricians and pipefitters.
To make sure the drawings were done properly, professional engineers needed to review the documents and attest to their accuracy. The drawings had to be created by a licensed engineer or by someone under their direct supervision, according to state law.
Either way, the drawings required a signature to ensure people could determine which engineer designed those sections of the reactor in case something went wrong.
The problem was, no one state agency was tasked with collecting and reviewing all of those plans. The state Board of Registration for Professional Engineers doesn't have the legal authority to inspect engineering worksites, and the NRC does not get into that level of detail in its review.
The federal regulators were primarily concerned with the conceptual designs for the reactors, not the detailed blueprints and intricacies of South Carolina’s engineering laws.
That left the door open to potential shortcuts. 
'Subject to interpretation' 
By the spring of 2012, before the nuclear reactors started rising out of the South Carolina and Georgia clay, Westinghouse attorneys were hard at work drafting a legal opinion.
It was a little over a month after SCANA received its delayed construction license from the NRC. Already, the South Carolina project had fallen behind the generic schedule that utility executives supplied to state regulators in 2009.
Trees had been cleared. Roads had been built. Huge holes had been excavated.
Pressure was building on the engineering side of things. Only 40 percent of the construction-ready design was reportedly complete. The deadline for federal tax credits loomed. SCANA had finally given the order to start pouring concrete and erecting steel.
But you can’t build something as complicated as a nuclear reactor without drawings in hand.
Amid this backdrop, SCANA’s leadership approached Westinghouse’s team. They asked the Pennsylvania-based company to provide an opinion of whether state engineering laws had to be followed when assembling the reactors.
In response, Westinghouse’s deputy general counsel drafted a 13-page legal opinion on May 7, 2012, arguing the engineering laws in South Carolina, Georgia and any other state where an AP1000 reactor was built didn't apply. They reasoned their federal licenses superseded state requirements.
Westinghouse’s vice president of engineering for new plants, the company’s director of engineering and procurement and its director of federal licensing for the AP1000 were all given a copy of the document. The director of nuclear engineering for Shaw, one of the original contracting companies, also was looped in. 
But Santee Cooper, the minority owner of the South Carolina reactors, was never notified of Westinghouse's opinion, according to officials with the state-run utility.   
The need for professional engineers to approve all of the reactor designs was a waste of time and money, Westinghouse's attorneys said. Getting the required stamps and signatures for the reactors at V.C. Summer and Plant Vogtle in Georgia would only "disrupt and frustrate," they said.   
Some drawings for the reactors did have to be handed over to state agencies such as the Department of Health and Environmental Control. 
In those cases, Westinghouse’s lawyers assured SCANA that everything would be done by the book. All of the office buildings and storage garages at the construction site that were reviewed by state regulators would be designed and approved by professional engineers, the attorneys said.
Not so for the nuclear reactors that are 30 miles away from South Carolina’s capital.
The setup was comparable to a hospital arguing it didn’t need doctors with medical licenses to treat patients, or a law firm hiring people who didn’t pass the bar to represent clients. It costs less money, but there are far fewer guarantees in the quality of the work.
The legality is even more questionable.
With no precedent in South Carolina, Westinghouse’s deputy general counsel warned her legal opinion could be “subject to interpretation.”
Troublemakers
As SCANA comforted utility regulators about increased budgets, temporary schedules and delayed completion dates, engineers said managers with Westinghouse and the Cayce-based utility ignored the concerns of some of their own professional staff.
Blueprints that were “issued for construction” started showing up at the southern tip of the Monticello Reservoir with so many flaws nearly every drawing was revised on site.
By the summer and fall of 2015, an estimated 600 engineering changes were made per month, according to an audit produced by Bechtel, the country’s largest civil engineering firm.
Some of those design changes required more paperwork than the original drawings, Bechtel employees found. It was suspected that Westinghouse’s design work was barely outpacing construction. The drawings, the audit found, were "often not constructible." 
The constant revisions made work for thousands of laborers even harder, and helped stall the build. Daily construction orders for craftsmen were held up. Requests for supplies would have to be rushed when the work plans were finally handed out. 
The reams of design changes, the Bechtel audit found, made it difficult for those construction employees to know if they were working off the right blueprints. 
It wasn’t until concrete was poured that workers realized a Westinghouse designer in Pittsburgh had doubled the amount of rebar needed in part of the power plant's foundation.
The steel reinforcing rods were so tightly packed that when workers poured the concrete for a section of the turbine building the slurry didn't flow properly. It left bubbles and empty spaces in the floor — a mistake that cost millions of dollars and months to fix.
The engineers at V.C. Summer did what they could to fix the problems as the designs arrived, but when several of them realized drawings weren’t officially "sealed," the issue became more serious.
A large part of the civil engineering designs that lay out the steel and concrete at the plant were stamped, engineers told The Post and Courier. That wasn't the case for the mechanical and electrical blueprints that outline the reactors' pipes, pumps, fans and electrical systems.
Concerns about the unlicensed engineering were raised up the chains of command in both Westinghouse and SCANA in past years, engineers said, only to be slapped down by more senior management. 
“It put us in a terrible situation,” one engineer said, “because if we raised the issue we’re tagged as troublemakers.”
SCANA and Westinghouse did not answer questions about the alleged complaints. 
Delays, incorrect parts, thousands of engineering changes, and billions of dollars in wasted money can be traced back to faulty drawings produced by unlicensed people working in Spain, North Carolina and Pennsylvania, those V.C. Summer engineers said.
“Everything else on this project was incompetence. This was criminal,” said another engineer who also asked to remain anonymous.
'Race to the bottom'
By the beginning of this year, the weight of the nuclear construction in South Carolina and Georgia was sinking Westinghouse and its parent company Toshiba.
Westinghouse, a business founded before light bulbs spread to every home and power lines webbed across the country, filed for bankruptcy at the end of March after contributing to a $9 billion loss for the Japanese conglomerate.
The bankruptcy left the utilities in South Carolina with a decision to make: Do you continue to build the reactors without your primary contractor? Or do you cut your losses and dump the projects that were already years behind schedule and billions of dollars over budget?
SCANA’s executives were told the fully integrated construction schedule that had been promised by Westinghouse didn’t exist.
Only 30 percent of the reactors were complete. The inaccurate designs had contributed to less than 0.5 percent of the reactors being built every month, engineers said.
It was the leaders of state-run Santee Cooper that ultimately decided the South Carolina construction couldn’t continue. SCANA’s executives relented. Lawmakers responded with disgust.
Since then, SCANA's knowledge of the unlicensed engineering has remained unquestioned in front of two special legislative committees. Westinghouse’s decision to disregard state law has gone unrecognized as the energy industry continues to assess the dimming future of nuclear power in the United States. 
The NRC requires the reactor vessels, coolant pumps and other vital nuclear components manufactured for the reactors to be designed by professional engineers, agency officials said. 
But the federal government doesn't have laws or regulations directly requiring the designs for the rest of the reactors be stamped and signed by licensed individuals. Those requirements are covered by the states, said Scott Burnell, a public affairs officer with the NRC.
Still, the companies building nuclear reactors in the United States are “always responsible for meeting relevant state and local requirements," Burnell said, 
Westinghouse and SCANA refused to answer whether they shared the 2012 legal opinion with the NRC, an outside law firm, the state attorney general or the South Carolina Department of Labor, Licensing and Regulation. They wouldn't say if anyone else had confirmed their legal position. 
Some of the design failures at V.C. Summer could have been picked up by engineering students in college, the engineers said.
The batteries that would maintain power for the reactors during an emergency were delivered to V.C. Summer, but were designed for the wrong electrical current. The giant, two-story-tall transformers arrived, but the multimillion-dollar electrical components were configured wrong. 
The shoddy drawings are what professional engineers refer to as a "root cause." It all stems back to the 2012 decision. 
“It was a race to the bottom," said one engineer. 
Tony Bartelme contributed to this report. 
Reach Andrew Brown at 843-708-1830 or follow him on Twitter @andy_ed_brown.

Thursday, November 02, 2017

Incident At Junk Facility Millstone-Examples Why Violation Levels Nation Wide Are Drastically Declining

It is secret deregulation and neutering the agency by the utilities!!!

This LER on duel plant trip in the mid 2016. Why do they have so much troubles with the important lines surrounding Millstone. The NRC should have got a violation over unreliable power lines.

Millstone once had three unit at their sites. Basically if two of three line tripped, the remaining lines would quickly lead to an overload. If the line would have tripped, it would lead to a loss of all power to the site and a hard trip scram to three plants. Now we only have two operating plants. Basically they had a circuit that would automatically reduce the load or trip plants such off site line load to 1650 MWes. The idea here was they would keep at least one plant operating to supply emergency power to the scammed plant. The NRC caught them in the dual plant special inspection they illegally removed this protection circuit because Millstone worried that if that circuit failed it would inappropriately scram a reactor.

1)Violation: Unreliable off site lines. 

2) Violation: Because of the heavy interest removing the circuit...the NRC should have made sure Millstone had adequate training and procedure for the next trip of two Line

3) Violation: threat of a two line trip or warnings, should have powered down 1650 MWe before any trip. 

4) Violation:  I don't see any crew briefing when they first took over the shift or when the first line was taken down...study up on what we have to do if the second line trips in procedures and this is how we anticipate doing if it occurs. 

5)Violation: Obviously something is wrong with simulator training. Is it modeled correctly and was there intense training on line trips and managing reactor in a emergency.

6) Not following boric acid procedures in a plant emergy 

The NRC based on 2014 duel plant trip special should have followed up...make sure
DOMINION NUCLEAR CONNECTICUT, INC. MILLSTONE POWER STATION UNITS 2 AND 3 LICENSEE EVENT REPORT 2014-006-00 MILLSTONE POWER STATION DUAL UNIT REACTOR TRIP ON LOSS OF OFFSITE POWER
Here is the new inspection. Boy, these guys got recently a lot of big LERs!!!
MILLSTONE POWER STATION – INTEGRATED INSPECTION REPORT 05000336/2017003 AND 05000423/2017003 
Annual Sample:  Unit 3 Rod Insertion Limit LO-LO Actuated During a Rapid Down Power to Support the Loss of Two Offsite Power Lines on August 14

a. Inspection Scope

The inspectors performed an in-depth review of Dominion’s cause evaluation and corrective actions associated with CR1068836 for an unplanned rapid power reduction on May 15, 2017.  Specifically, the loss of two 345kV offsite power lines caused Unit 3 operators to rapidly reduce power from 1127 MWe to 900 MWe as required by Technical Requirements Manual  3.8.1, “Electrical Power Systems,” to prevent grid instability.  

The inspectors assessed Dominion’s problem identification threshold, cause analyses, extent of condition reviews, compensatory actions, and the prioritization and timeliness of corrective actions to determine whether Dominion was appropriately identifying, characterizing, and correcting problems associated with this issue and whether the planned or completed corrective actions were appropriate.

b. Findings and Observations

No findings were identified.

On May 15, 2017, Millstone station experienced the loss of two 345kV offsite feeder lines and was directed by the grid operator to rapidly reduce station output power to 1725 MWe within 25 minutes.  Millstone Unit 3 entered TRM under requirement 3.8.1, action B, which required reducing total station output to 1650 MWe within 30 minutes.  Both units entered C OP-200.8, “Response to ISO New England / CONVEX Notifications and Alerts,” and coordinated the load reduction to achieve the required downpower.  Unit 3 entered AOP 3575, “Rapid Power Reduction,” and commenced a power reduction at 3 percent/min from 1267 MWe to 900 MWe.   Despite the fact that one offsite 345kV line was already out of service, Unit 2 and Unit 3 had not predetermined how much of the total power reduction would be shared by each unit if a second line was lost.  Coordination of this effort took 10 minutes to complete which caused a delay in starting the power reduction which could have been performed concurrently, and resulted in a shorter time (20 minutes) to reach the rapid power reduction target.   Upon entry into AOP 3575, the operators calculated and added an initial amount of boric acid that should be sufficient to complete the power reduction.  However, a recent change to AOP 3575 directed the operators to use a value for boric acid reactivity effectiveness of 15 (gallons of boric acid)/(percent power) which was appropriate for beginning of life, but was non-conservative for end of life reactivity conditions.  The correct value for end of life is approximately 18 gal/percent.  The operators correctly followed AOP 3575 and computed the amount of boric acid to be added based on the 15 gal/percent as directed and thus under-estimated the amount of boric acid to be added to maintain the shutdown margin by approximately 20 percent.   During the rapid power reduction, the control rods continuously inserted in automatic as designed.  The operators slowed the power reduction rate from 3percent/min to  1 percent/min at 1650 but did not increase the boration rate or add more boric acid despite the fact that the control rods were approaching the rod insertion limit (RIL).  Step 6.h of AOP-3575 requires the operators to monitor the rapid
Violation: they lost control of power. It should have been a violation on Unit 3 
downpower parameters and adjust (decrease) loading rate, boration time and flow rate, or rod position as necessary.  Although the operators reduced the power reduction rate, this change would have little effect on the final control rod position and approach to RIL as the RCS temperature deviation (Tave – Tref) was +4°F and control rods were stepping in rapidly.  As the control rods approached RIL, additional boric acid was required to be added to prevent exceeding the rod insertion limit which was a warning alarm for a pending loss of adequate shutdown margin.    

At 1658, Unit 3 reached the required target of 900 MWe and the “RIL LO” alarm annunciated.  The required action in AOP 3575, step 7.m, for this event is to “increase the boration flow rate”.  Although the initial rapid boration had been completed and should have been sufficient, the procedure directs the operators to immediately restart the boration to prevent the RIL LO-LO alarm.  At 1659, the RIL LO-LO annunciator alarmed.  The operators responded at 1703 by rapidly borating until sufficient additional negative reactivity was added so the control rods could be withdrawn to clear the RIL alarm, which occurred at 1705.  TS 3.1.3.6 requires the rods to be maintained above the RIL.  The action statement is to either restore rods above the RIL setpoint or reduce power to clear the RIL setpoint within two hours.  The operators entered TS 3.1.3.6 and restored the control rods above RIL within six minutes.   Two minor performance deficiencies were noted during this inspection.  The first involved procedure AOP 3575, which directed the operators to calculate a boric acid addition that should have been sufficient to complete the rapid downpower without control rods inserting below RIL alarms.  However, the procedure assumed beginning of life conditions in the core.  The core was operating at the end of life when the reactivity coefficients and power defect were different.  These differences resulted in an insufficient amount of boric acid being calculated and added to the RCS.  This procedural inadequacy was identified by the licensee in the apparent cause evaluation and was promptly corrected by a revision to AOP 3575.  

A second minor performance deficiency was identified by the inspectors. The inspectors noted that operators did not adequately control the reactivity balance during the power reduction.  AOP 3575, step 6.h requires the operators to monitor the rapid downpower parameters and adjust (decrease) loading rate, boration time and flow rate, or rod position as necessary.  The operators reduced the power reduction rate but did not add additional boric acid as the control rods approached RIL alarm.  Furthermore, steps 7.k, l and m, provided specific direction to immediately increase boration flow if the RIL LO alarm occurs during a power reduction that was requested by the grid operator.  Contrary to this direction, the operators did not address the need to add additional boric acid to the RCS to properly control the reactivity balance during the rapid downpower until after the RIL LO-LO annunciator had alarmed.  After the event, operators discussed this issue during the 4.0 crew debrief; however, the inspectors identified that this issue was not appropriately captured in the CAP and corrective actions associated with the event failed to address the operator performance issues concerning reactivity management.  However, the inspectors noted that appropriate corrective actions were taken to address this issue through changes to AOP 3575 and through changes made to operator training, which were addressed with a systematic approach to training, during training cycle 17-03, June 20 through August 11, 2017.