Senator Markey: Pilgrim Shutdown and Special Inspection

From: Michael Mulligan <steamshovel2002@yahoo.com>
To: ****************************************
Sent: Friday, March 15, 2013 10:50 AM
Subject: Pilgrim nuclear plant: Request shut down and NRC special inspection over these events

Dear Senator Markey,

Honestly, how sweet would that be, with Senator Sanders and Senator Markey?

I recently discovered from Pilgrim plant insiders that their plant was on the fourth safety relief valve leak. These are extraordinarily important components in a nuclear plant and they dictate overpressure control of the reactor vessel and control core cooling in most modes. To this day, the leak hasn't been explained in our media and even in the any NRC documents. They are right now restricted to 94% because of a leaking SRV valve.

 

　

They had reliability issues with the "two stage" valves for years...then they purchased and installed "new three stage" valves in around 2011. The leaks of these new expensive nuclear safety valves have caused two plant shutdowns, another leak occurred just before the Nemo blizzard and required them to be restricted to 84% reactor to stop the leak. They were preparing to shut down the plant when the blizzard forced them into a trip. A week or so after the restart, so called fixing the valves, another leak began and it secretly forced them into 94% a power restriction. I verified it was a leaking SRV valve from the region 1 public relation spokesmen(Neil Shaheen) and I signaled to the NRC I was working on inside information.

I basically requested that Governor Patrick and AT Coakley request an immediate plant shutdown to repair the valves and demand an NRC special inspection. I believe there is a design or manufacturing defect in all the valves making all the valves INOP. If one valve becomes inop (broken), then the plant is required to be shut down in 24 hours according to tech specs.

 

　

You and me worked on the Palisades nuclear plant safety tank leak and it dripping into the control room together. I submitted a 2.206 on it and the NRC told me they were really sensitive, in phone meetings to me, about these issues because you were involved. I had the plant inspectors and region III big wigs talking to me in a phone bridge because of you.

I was in the navy many years ago and I was stationed, working in the back end of a fast attack nuclear submarine. I worked at Vermont Yankee as a licensed nuclear plant operator till 1993, I raised safety and was fired for that. The NRC today is terribly dysfunctional and is dangerous to our nation.

These nuclear utilities are facing a superstorm over low grid prices, low electric demand and natural gas fracting. I am a committed nuclear plant safety advocate and my 2.206s and documents, let alone blogging, is all over the NRC document system. Honestly, our electric system and grid system are so messed up and dysfunctional...local, state and federal oversight.

This is who I submitted a concern to in the Massachusetts's Attorney General’s office and it includes my NRC 2.206 petition. Have you ever read the children’s book ‘Mike Mulligan and His Steam Shovel’ (my real name):

　

From: ago (AGO) < ago@state.ma.us>
To: Michael Mulligan <steamshovel2002@yahoo.com>
Sent: Friday, March 8, 2013 2:07 PM
Subject: RE: Safety Relief Valves at the Pilgrim Nuclear Station

Dear Mr. Mulligan:

Thank you for contacting the Office of Attorney General Martha Coakley. I am writing to acknowledge receipt of a recent message you sent to the Office. Your message has been forwarded to the appropriate division for response. Please note that you may also wish to contact our office directly by telephone at 617-727-2200, and a live operator may be able to direct you. As always we appreciate your patience.

Sincerely,

Constituent Services Coordinator
Public Inquiry & Assistance Center
Office of Attorney General Martha Coakley

-----Original Message-----
From: Michael Mulligan [mailto:

steamshovel2002@yahoo.com]
Sent: Friday, March 08, 2013 10:55 AM
To: Email Correspondence (AGO)
Subject: Safety Relief Valves at the Pilgrim Nuclear Station


Dear Attorney General Coakley,

I called your agency's tip line yesterday to explain my issues and they connected me to a place where I could leave a recorded message for some kind of complaint. This is a written follow up to that.

I worked as a licensed nuclear operator at a sister plant Vermont Yankee for many years and I was in the Navy stationed on a nuclear fast attack submarine. Got fired for raising safety issues at Vermont Yankee in 1992.

Ultimately, my aims are to transform the nuclear regulatory commission. I support the good guys in the plant control room...I think telling the truth is good for our nation and it makes the nuclear industry and nuclear plant more safe and strong.

My name is all over the NRC's Adams document system...I am an expert on their document system.

It would be nice if the Massachusetts joined my petition in some way...gained me some leverage and status over the NRC ...help me gain the documents and information not so far disclosed. I would like Massachusetts and the Attorney General to demand an immediate shutdown of Pilgrim to repair/replace these valves...to demand from the NRC a thorough "special inspection" over these safety relief valves. I discovered the forth new leak from a plant insider. I think this is a generic issue at many plants.

This is a cover-up since the nemo blizzard restart. You have to have $100,000s worth of special nuclear education that gets you to look in the right direction and ask the right question...instead of the NRC and the Pilgrim plant to thoroughly self disclose to a community. It is just not right...it is honesty and integrity! Do you know the difference between state oversight between Massachusetts and Vermont?

Personally, I think the NRC is thumbing their nose at Massachusetts and the Attorney General's office over the recent court relicensing case. We are the top dog here in Massachusetts with a nuclear plant...we can allow Pilgrim to operate in any manner we wish. I am certain the NRC is looking over their shoulder to the nuclear industry with recent events...the states will never have any influence over the safety of a nuclear plant. It is similar to the Vermont Yankee and Vermont state court case. The agency and industry are edgy over this with a lot of money on the line...so they are allowing the Pilgrim Plant to operate outside the lines as a showcase to the industry...show that NRC will always dominate over plant operation even if they are unsafe.

The industry with natural gas fracting, low electric demand and cheap electric grid prices has never been as economically threatened as it is now with declining stock prices and budget cutbacks the plants. The NRC is totally controlled by the rabid mad dog congressional extreme right wing republicans. The Nuclear Regulatory commission is in terrible shape.

I grew up in the Pine Point section of Springfield Ma!

Mike Mulligan
Hinsdale, NH
16033368320


...March 7, 2013

Bill Borchardt
Executive Director for Operations
U.S. Nuclear Regulatory Commission
Washington, DC 20555-0001

Dear Mr. Bochardt,

Request an emergency and on a exigent bases, that the Pilgrim Nuclear plant be immediately shut down.

Don't tell me just before the Nor'easter Nimo struck the Pilgrim plant with a leaking safety relief valve and down at 80%, Entergy was intending to operate that plant with a defective leaking safety relief valve till the next refuel outage? Tell me it ain't so. It certainly looks like with the current leak today that is intending to operate till next month.

Is the game plan today to incrementally increase reactor power from 94% by 1% to see if a new SRV leak is getting worse?

Timeline:

1) New three stage safety relief valves installed in the plant around May 2011.

2) First leak and shut down on Dec, 26. 2011 (SRV RV-203-3D).

3) Second leak and shut down on Jan 20, 2013 (SRV RV-203-3B).

4) Third leak occurred a few weeks later and the plant was at a restricted to 84% power...the Nemo blizzard tripped the plant. The NRC promised these valves are fixed before startup. (SRV RV-203-3B).

5) Basically, they operated for 20 days at 100% power operation post shutdown, then reported on Feb 27 the plant is operating at 94% power with no explained reason until today. The reason for the down power was kept secret from the public.

6) Today March 7, 2013 I called the NRC's public relation people and the agency told me they had indications of a leak and that is why the plant is at a restricted power level.

Don't forget the repetitive nature of the recently broken scram discharge volume vent and drain valves...implies Entergy is incapable of maintaining safety components of a nuclear plant.

The repeated nature of the failure of the safety relief valves means Entergy doesn't know the mechanism of the failure...it is a common mode failure. The design and manufacture of these valves are defective and it is extremely unsafe to operate a nuclear plant with all safety relief valves being INOP. A condition adverse to quality...

The NRC should have made a public comment about the new leaking safety relief when they first became aware of the leak. The implication is the agency was going to allow the plant to operate with unsafe SRVs until the refueling outage next month. The NRC is involved in a serious cover-up of an extremely unsafe operation of a nuclear power.

1) Request an immediate shutdown the Pilgrim Plant.

2) The is the second time I requested a special NRC inspection concerning the defective SRV valves.

3) Not allow the plant to restart Pilgrim until they fully understand the past failure mechanisms of the four bad new three stage safety relief valves.

4) Request the OIG investigate this NRC cover-up to keep an unsafe nuclear plant up at power.

References:

The Popperville Town Hall (my blog)

http://steamshovel2002.blogspot.com/

"Pilgrim's Safety Relief Valve Leaking Boondoggle"http://steamshovel2002.blogspot.com/2013/02/pilgrims-safety-relief-valve-leaking.html


Sincerely,

Michael Mulligan
PO Box 161
Hinsdale, NH 03541
16033368320steamshovel2002@yahoo.com

The NRC is setting up a Pilgrim SRV 2.206 with this e-mail below. I got a -100% of ever being successful or getting more information from this process. Most of these NRC officials in region 1 and 3 are fully aware of my reputation. How about helping me reform the NRC’s 2.206 petition process (you never know?)? You got to keep the message of nuclear safety directly in front of these people:

From: "Guzman, Richard" <Richard.Guzman@nrc.gov>
To: "'steamshovel2002@yahoo.com'" <steamshovel2002@yahoo.com>
Sent: Thursday, March 14, 2013 3:05 PM
Subject: RE: 2.206: Pilgrim Nuclear Plant SRV Request for Emergency Shutdown

Mr. Mulligan,

 

Your 2.206 petition by email dated March 7, 2013, was assigned to the Office of Nuclear Reactor Regulation (NRR) for review. My name is Richard Guzman, NRR project manager in the Division of Operating Reactor Licensing, and I have been assigned as the petition manager for your petition. As you’re aware, the 2.206 process is a public process, and your petition will be made a publicly available document in the NRC’s Agencywide Documents Access and Management System (ADAMS).

In accordance with the 10 CFR 2.206 process, the Petition Review Board (PRB) is offering you an opportunity to address the PRB to provide any relevant additional explanation or support for your petition before the it makes an initial recommendation. Please let me know whether you would like to address the PRB.

Thanks,

Rich Guzman

Sr. Project Manager

NRR/DORL/LPL1-1

US NRC

301-415-1030

From:

Michael Mulligan [

mailto:steamshovel2002@yahoo.com]
Sent: Thursday, March 07, 2013 12:33 PM
To: newstip@globe.com; NRC Allegation
Subject: 2.206: Pilgrim Nuclear Plant SRV Request for Emergency Shutdown

Dear sir,

I called this into your hotline by telephone and left a message to a reporter an hour or so ago. This is just a follow-up.

I'd like to get Gov Patrick to demand an immediate Pilgrim shutdown and demand a special investigation of these events.

Mike

So the below is my 2.206 request to the NRC. You'd do me a favor if the BG calls our region I public relation people...Neil Shaheen.

March 7, 2013

Bill Borchardt

Executive Director for Operations
U.S. Nuclear Regulatory Commission
Washington, DC 20555-0001

Dear Mr. Bochardt...

 

So what am I after from you and your office? If the NRC knows you are paying attention to these Pilgrim plant problems, my petition, then they will cater to me. I am just trying to get out all the information in the documents and get the issues fully ventilated. I will be trying to get a phone meeting with the local inspectors and regional big wig officials. I always treat the NRC officials with dignity and respect....but they do irk the hell out of me. I have spent many many hours talking to NRC officials. A little bit of media attention from you would also help. Course, I am always open to better ideas with how to treat this. I don’t care who gets credit with this!

I always have no anonymity or confidentiality needs...as a given, I will always protect my insider contacts.

Sincerely,

Mike Mulligan

PO box 161

Hinsdale, NH 03451

16033368320 (call anytime)

steamshovel2002@ yahoo.com

My LaSalle nuclear 2001 2.206 petition

So basically the agency is using wordsor rules trickstersism.  What is the same as having no rules, it is having too many rules? They can pull an obscured sentience out in a rule to throw at me and then spin the meaning in the industry's direction.

I am in my best right here...I am at the apex of doing my job.  They were answering in this thorough way because I was representing the New England Coalition. I wish I had an entity whom I could represent to elevated my status to the NRC. They know now i only represent myself.

Along with LaSalle, there was Limerick with their popping open relief valves in this time frame. I got the feeling the NRC was rationalizing away all leaks from the reactors thoughout the nation. This was a group thing with rationalizing away the threat of reactor leaks. SRVs being one, then as a general concern misusing safety systems because of poor maintenance to maintain commercial operation. They could spin a host of rules around so nuclear vessel core leaks didn't matter. Guys, get real, you can spin around any  rule to fit any agenda.

These guys were going crazy in the beginning with their pipe dreams of building the new nukes...pushing corporate and plant capacity factor. We were in a nuclear industry tulip mania. I chose the region III because I got wind these guys were in so much trouble.  Balls to the walls deregulation fanatic president  Bush, who hated all government regulations, just got elected. Clinton was much like president Bush. So I knew the NRC at  all through 2001 was spinning out of control.

People who know me think I can see premonitions. I can spin organizations' behaviors in my head and I am good at predicting result. What gets to four srvs leaks on four new srvs valves is deep behavior of a group of peope. I wouldn't have spent so much time on LaSalle or Region III if I din't know they were in big trouble in 2001.

Davis Besse leading fro, 1998 to 2001 was a terribly leaking ship...unbelievably reckless with downplaying a host of reactor vessel leaks to boost  capacity factor and  support a weakening stock price. Davis Besse leading up to this had very good grades from the NRC...post hole in the head, the NRC admitted they severely inflated the grade of Davis Besse in the lead up to this near miss.

The very serious Davis Besse hole in the reactor head accident discovered in March 2002...



 March 12, 2013:

November 29, 2001

(So I added the link to this NRC document.)




Mr. Michael Mulligan
New England Coalition on Nuclear Pollution
5 Woodlawn Lane
Hinsdale, NH 03451

Dear Mr. Mulligan:

Your e-mail dated September 27, 2001, and addressed to Mr. Victor L. Dricks for
Dr. William D. Travers, Executive Director for Operations, has been referred to the Office of Nuclear Reactor Regulation (NRR) pursuant to 10 CFR 2.206 of the Commission’s regulations. A copy of your e-mail and all supplements are enclosed for completeness. Noting your request that the Nuclear Regulatory Commission (NRC) take enforcement action against the LaSalle County Station, Units 1 and 2, (LaSalle), the staff has processed your request following the guidance in Management Directive 8.11, "Review Process for 10 CFR 2.206 Petitions." You requested the following NRC enforcement-related actions:

1. Both units be immediately shutdown for a lengthy maintenance period to replace leaking safety/relief valves (S/RVs).

2. The NRC perform an immediate emergency inspection on the S/RV problems atLaSalle and an assessment of other similar large relief valves at other Exelon Generation Company, LLC, (Exelon, licensee) facilities.

3. The NRC perform a detailed inspection on the suppression pool temperature increases, in-leakage problems, and extended use of the residual heat removal (RHR) system in the suppression pool cooling (SPC) mode during this past summer.

As the basis for your request, supplemented by information you provided to Mr. William A. Macon, Jr., on October 3, 2001, you stated the following.

1. NRC Inspection Reports 00-12, 01-02 and 01-03 for LaSalle indicate multiple Unit 1 and Unit 2 S/RVs have excessive internal seat leakage. You further suggest that the NRC displays a "reckless indifference to safety" regarding S/RV leakage and other degraded components which create "unacceptable risks to the surrounding community."

2. NRC Inspection Report 00-11, which references a LaSalle policy directive (LOP-CM-03) that addresses frequent suppression pool cooling and mixing, indicates many years of living with degraded component problems and allowing suppression pool temperature increases up to the 105 Flimit. You further suggest that degraded plant operations are bumping past conservative safety limits and analysis, and that the NRC is being "deceptive" and "amoral" regarding its technical reviews of the industry’s engineering analyses.

3. Operation of the RHR system in the SPC mode is not meant to facilitate normal commercial plant operations. Safety systems are designed to be maintained in a standby state and only run when absolutely necessary. The industry has declared that running these components excessively creates the condition which leads to excessive wear and increasing failures. You further suggest the NRC has become a "one way check valve for the industry" by permitting longer testing timeframes and reduced testing for the nuclear industry’s benefit.

You addressed the NRC’s petition review board (PRB) by teleconference on October 12, 2001, to clarify your petition. A transcript of the meeting is enclosed as a supplement to your petition. The results of that discussion have been considered in the PRB's determination regarding your request for immediate action and whether or not the petition meets the criteria for consideration under 10 CFR 2.206. The staff has concluded that your submittal does not meet the criteria for consideration under 10 CFR 2.206 because your petition presents no significant new information and only raises issues that have already been the subject of NRC staff review and evaluation on the LaSalle facility and other similar facilities (e.g., Quad Cities, Fitzpatrick).

Your petition, supplemented by information you provided to Mr. Macon on October 9, 2001, raises additional concerns about potential NRC misconduct. You state that the agency has ignored known problems with leaking S/RVs and RHR reliability at LaSalle and throughout the industry. The staff is treating these concerns as assertions of impropriety by NRC staff and has referred them to the Office of the Inspector General. Although the staff has concluded that your submittal does not meet the criteria for consideration under 10 CFR 2.206, the staff has reviewed the relevant technical issues and has developed the following response to your concerns:

EVALUATION

LaSalle County Station, Units 1 and 2, currently operates in accordance with a set of improved technical specifications (TSs) based on NUREG 1433, Revision 1, "Standard Technical Specifications, General Electric Plants BWR/4," dated April 1995, NUREG-1434, Revision 1, "Standard Technical Specifications, General Electric Plants BWR/6," dated April 1995, and on guidance provided in the Commission’s "Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors," published on July 22, 1993 (58 FR 39132). These technical references, prepared by the NRC staff, have been extensively reviewed by the industry, professional organizations, academic institutions, and the public. The staff prepared the Safety Evaluation (SE) for the LaSalle improved TS conversion in accordance with these references and NUREG-0800, "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants," dated July 1981. On March 30, 2001, the Commission issued Amendment 147 to Facility Operating License No. NPF-11 and Amendment No. 133 to Facility Operating License No. NPF-18 for the LaSalle County Station, Units 1 and 2, respectively. The licensee implemented the improved TS at LaSalle on May 1, 2001, which are currently the licensing basis under which NRC inspectors monitor plant activities, evaluate if NRC requirements are violated, and, if a violation is found, determine its effect on plant safety and risk. Excerpts from the LaSalle TS and bases are enclosed for reference to clarify the staff’s evaluation of your safety concerns.

Safety/Relief Valves (S/RVs)

In your 10 CFR 2.206 petition and in previous communications with the staff regarding LaSalle and other facilities (e.g., Limerick, Prairie Island, Susquehanna), you have expressed concerns regarding the degradation of S/RVs, the amount of leakage which is considered to be acceptable for S/RVs and other large relief valves, and the surveillance testing interval which is acceptable to satisfy ASME Code requirements. The staff has responded to you on several occasions, most recently on September 14, 2001, in response to your June 21, 2001, concerns regarding leakage of large remotely controlled relief valves. The NRC staff considers some leakage to be acceptable without affecting plant operation or safety, and, in fact, all S/RVs may leak without necessarily rendering them mechanically inoperable and incapable of performing their safety functions in the event of a reactor overpressurization event. As long as TS Limiting Condition for Operation (LCO) 3.4.4 and Surveillance Requirement (SR) 3.4.4.1 are satisfied (see enclosed excerpts), no NRC enforcement-related action is warranted. The staff further considers that NRC requirements are being met to ensure S/RVs are monitored and maintained in a condition that ensures they will perform their safety functions.

Safety-related components such as S/RVs are within the scope of the Maintenance Rule (10 CFR 50.65). The Maintenance Rule requires that licensees monitor the performance or condition of components, such as S/RVs and other large relief valves, against licensee established goals commensurate with safety, taking into account industry-wide operating experience. Licensees must take corrective action when these goals are not met. The NRC has determined that the Boiling Water Reactor (BWR) Owners Group and individual licensees at LaSalle and other facilities have significantly improved the performance of three-stage S/RVs and two-stage S/RVs as demonstrated by plant-specific operational experience and test data. The NRC staff does not believe there is a generic problem regarding the operability of S/RVs, despite known component degradation and leakage problems. These are maintenance issues which fall within the scope of the licensee’s maintenance programs and corrective action programs, and not within the scope of direct NRC enforcement. The licensee has indicated that it plans to replace the current hard-seat S/RVs with soft-seat S/RVs during upcoming outages to fix the leakage problems, and the staff is satisfied that these planned corrective actions will be sufficient. The staff continues to monitor the S/RV leakage problems, but neither the NRC staff’s evaluation, nor industry operational data, indicates that the currently installed S/RVs pose a risk-significant safety concern.

Suppression Pool Average Temperature

In your 10 CFR 2.206 petition you have expressed concerns regarding the licensee approaching TS limits on suppression pool temperatures. This is an operating issue which falls within the scope of the licensee’s operating procedures, and not within the scope of direct NRC enforcement. As long as LCO 3.6.2.1 and SR 3.6.2.1.1 are satisfied, no NRC enforcement related action is warranted. TS limits are not safety analysis limits, and approaching a TS limit is within the bounds of acceptable plant operation as long as the limit is not exceeded. NRC inspectors continue to monitor plant activities to ensure NRC requirements are met and plant procedures are followed. There has been no indication that these TS limits have been exceeded or plant procedures violated, nor has there been any other indication to suggest that the current safety analyses are non conservative.

Residual Heat Removal (RHR) Suppression Pool Cooling

In your 10 CFR 2.206 petition, you express concerns regarding the degradation of the RHR system, excessive run times of the RHR subsystems, and the operation of safety systems such as RHR during regular plant operation rather than maintaining them in a standby state. Although there is no TS limit or other licensing restriction on run times for the RHR pumps at LaSalle, there are starting limitations on the pumps and they are required to be run quarterly (every 92 days) in accordance with the inservice testing (IST) program. The pumps are, in fact, designed for extended operation for use during the long term core cooling mode of operation.

As long as LCO 3.6.2.3, SR 3.6.2.3.1 and SR 3.6.2.3.2 are satisfied, no NRC enforcementrelated action is warranted. The staff considers that NRC requirements are being met to ensure RHR suppression pool cooling subsystems are monitored and maintained in a condition that ensures they will perform their safety functions. Safety-related components such as RHR pumps and valves are within the scope of the Maintenance Rule (10 CFR 50.65). Licensees must take corrective action when licensee established goals are not met. The NRC staff does not believe there is a generic problem regarding extended use of the RHR system in the SPC mode, as far as normal system reliability and operability are concerned. Concerns about excessive wear and increased risk of failures of RHR system components are maintenance issues which fall within the scope of the licensee’s maintenance programs and corrective action programs, and not within the scope of direct NRC enforcement. The staff continues to monitor the safety system performance of RHR and other systems, but neither the NRC staff’s evaluation, nor industry operational data, indicate that the currently demonstrated level of performance at LaSalle poses a risk-significant safety concern.

However, the NRC staff shares your concerns about extended use of the RHR system in the SPC mode and the potential for water hammer in the RHR system during a design basis loss of coolant accident (LOCA) coincident with a loss of offsite power (LOOP) while the system is aligned in this mode. This issue has been previously identified in NRC Information Notice (IN) 87-10, "Potential for Water Hammer During Restart of Residual Heat Removal Pumps," dated February 11, 1987, and Supplement 1, dated May 15, 1997. This supplement specifically addresses the increased use of RHR pumps in the SPC mode due to leaking S/RVs. The concern is that during a design basis LOCA coincident with a LOOP, the LOOP, subsequent valve realignment, and large elevation differences may allow portions of the RHR system to drain down to the suppression pool, leaving voids in the RHR piping. When the emergency diesel generators reenergize the emergency buses in response to the LOOP, the RHR pumps will start and possibly cause water hammer damage in the voided RHR loop.

In 1993, NRC inspectors expressed concerns that the licensee had not adequately addressed IN 87-10, and the licensee subsequently performed additional analysis and testing and concluded that the potential for severe water hammer was possible. As a result, Sargent and Lundy performed water hammer analysis EMD-067982, "Evaluation of Potential Water Hammer In Residual Heat Removal System," Revision 0, dated February 18, 1994. This report concluded that although a water hammer would occur, the RHR system would maintain its pressure boundary integrity, structural stability, and functional capability during the water hammer event. NRC inspectors noted that plastic deformation and ovalization of system piping as well as snubber failure were also predicted. These results were subsequently documented in the LaSalle updated final safety analysis report (UFSAR).

In December 1995, General Electric Report NEDC-32513, "Suppression Pool Cooling and Water Hammer," was issued to document the conclusion of a General Electric review of the generic water hammer issue. In that report, the following conclusions were documented:

Operation of the RHR system in the SPC mode has been expected to be an infrequent occurrence during normal operation. As a result, the original LOCA design basis and supporting analysis only assumed initiation of the ECCS/LPCI [Emergency Core Cooling Systems/Low Pressure Coolant Injection] mode to be from a standby configuration.

The frequency of occurrence of a LOOP/LOCA coincident with the RHR system being in the SPC mode is less than the probability of events considered in the design of BWRs (&lt; 1.0x10-6 per year, per ANSI/ANS-52.1, "Nuclear Safety Criteria for the Design of Stationary Boiling Water Reactor Plants").

Although LOOP/LOCA occurrence during secondary modes of operation (such as SPC mode) may not have been included in the original design basis, the staff has determined that the increased use of SPC mode, possibly beyond the frequency defined as "short operational periods," would require analysis of the event and the corresponding draindown and water hammer. The LaSalle licensing basis contains no specific restrictions regarding the time in which RHR may be operated in the SPC mode and the 1994 water hammer analysis concludes that the RHR safety function will be maintained despite the potential for severe water hammer, which indicates that LaSalle has been operating within currently acceptable limits and analyses.

(The below talking about, I was banging on the NRC before April/May 2001. This got the whole industry to reevaluate running invaluable safety systems to maintain commercial operation)

Due to the number of S/RVs leaking at both LaSalle units during the current operating cycles, and the expected increased use of RHR in the SPC mode during the summer months with elevated ultimate heat sink (UHS) temperatures, NRC inspectors began reviewing the LaSalle water hammer analysis during April/May 2001 and began an iterative series of discussions with the licensee. As late as September 17, 2001, prior to your petition on September 27, 2001, NRC Inspection Report 01-10 notes that the inspectors reviewed selected Operability Evaluations and Condition Reports related to the leaking S/RVs and a licensee management decision to operate one train of the Unit 1 RHR system continuously in the SPC mode, and identified this issue as an Unresolved Item (URI 50-373/2001010-02).

This unresolved item involves regulatory interpretations unrelated to the technical concerns raised in your petition. For example, the staff currently has a concern that the 1994 RHR water hammer analysis does not meet the criteria specified in Appendix F of Section III of the ASME Code. The licensee has commissioned an independent contractor to review the analysis and determine whether the analysis is reasonable to demonstrate system functionality. Additionally, the staff is reviewing the overall adequacy of the LaSalle water hammer analysis and the applicability of the recently revised 10 CFR 50.59 change control process to this issue.

These ongoing discussions primarily involve regulatory interpretations and do not involve any new technical issues which have not already been the subject of NRC staff review and evaluation (e.g., Fitzpatrick in 1996, Quad Cities in 1997). Your petition does not present any significant new information which may be relevant to these discussions. The staff continues to monitor the LaSalle water hammer analysis issue and will employ whatever regulatory actions are appropriate, including enforcement action if warranted.

CONCLUSION

Based on the above, the NRC staff has concluded that your submittal dated September 27, 2001, supplemented by information provided on October 3, 2001, does not meet the criteria for consideration under 10 CFR 2.206 because your petition presents no significant new information and only raises issues that have already been the subject of NRC staff review and evaluation on the LaSalle facility, other similar facilities (e.g., Prairie Island, Susquehanna, Limerick, Fitzpatrick, Quad Cities), and on a generic basis, for which the issues have been resolved and the resolutions are applicable to LaSalle. No NRC enforcement-related action is warranted based upon the information you have presented.

Mr. Mulligan, please understand that if a violation of NRC requirements is found during NRC inspections or brought to the attention of the NRC by either plant personnel or other individuals, there are basically two mechanisms used by the NRC to address the problem based upon its effect on plant safety and risk. If the violation is of very low safety significance, it will be discussed in an inspection report with no formal enforcement action. The utility is expected to deal with the violation through its corrective action program, correcting the violation and taking
steps to prevent a recurrence. If the NRC risk evaluation finds that the violation has a higher risk significance, a Notice of Violation will be issued to the licensee which may or may not involve a civil penalty. A Notice of Violation requires the licensee to respond formally to the NRC with its actions to correct the violation and what steps it will take to prevent the violation from occurring again. Both mechanisms involve a public process and all documentation is available for public review.

In summary, the NRC staff concludes that no violation of NRC requirements exists at the LaSalle County Station, Units 1 and 2, which warrants NRC enforcement-related action.

Your concerns related to excessive leakage of S/RVs, suppression pool temperatures approaching operational limits, and extended use of the RHR system in the SPC mode have been previously addressed and evaluated by the staff. The NRC, therefore, does not intend to review your concerns under the 10 CFR 2.206 petition process for the aforementioned reasons.

Thank you for bringing these issues to the attention of the NRC.

Sincerely,
/RA/
John A. Zwolinski, Director
Division of Licensing Project Management
Office of Nuclear Reactor Regulation
Docket Nos. 50-373 and 50-374
Enclosures: As stated
cc w/Enclosures: See next page

So why don't these guys join me to shut down and replace the leaking new SRV valves and demand a special inspection from the NRC...

Pre-trial begin for the Pilgrim 14
Submitted by Editor on Mon, 03/11/2013 - 11:13am

Pilgrim 14 Court Hearing Pre Trial Hearing begins March 13, 2013

The NRC granted the request for operations to continue at PNPS for 20 more years over the objections of Governor Deval Patrick, Attorney General Martha Coakley, State Senator Dan Wolf, Congressmen Edward Markey and Bill Keating along with others. The Pilgrim 14 trial will adduce evidence of the imminent public dangers inherent in the operation of PNPS and the lack of concern for public safety or preparedness by the NRC and Massachusetts Emergency Management Agency.

Here is their report on it

They made every nuke plant in the USA recheck their power scheme so that if they lose a phase it would trip the plant from the grid and then wholly depend on the diesel generators.

 Licensee Event Report 2012-001-00

The difference between these guys and I was 1 year before the plant accident I make a complaint to the governor of Vermont about a intermittent short on a fuel pool pump motor. I complained they needed to call it INOP...be shutdown in 30 days of the discovery. Another one is they made believe it was operable for year even as they had it danger tagged out. When I complained, it was 11 months since they should have been shutdown. The electric motor wasn't in stock...they were forced to get a contractor to manufacture this nuclear grade safety motor it for Vermont Yankee. The inisial company no longer carried this kind of electric motor line.

I predicted we were heading for a bad accident with many broken components in the letter to the governor. What caused the LOOP was management taking shortcuts out in the switchyard in order to replace the switchyard batteries. We shorted out both sides of the redundant emergency shityard control power. We had tons of broken and degraded equipment...then severely throttled RHR service water and diesel generator cooling to boost pressure to a rad monitor.

What's the 2006 Danvers Massachusetts chemical explosions, the New England Compounding Center and the Pilgrim Nuclear power Plant got in common..

It is that Massachusetts doesn't want or have the direct oversight of these bad actors and have the appropriate laws and codes to oversee bad businesses and corporations...

Dear Attorney General Coakley,

From: Michael Mulligan <steamshovel2002@yahoo.com>
To: "ago@state.ma.us" <ago@state.ma.us>
Sent: Friday, March 8, 2013 10:55 AM
Subject: Safety Relief Valves at the Pilgrim Nuclear Station


Dear Attorney General Coakley,

I called your agency's tip line yesterday to explain my issues and they connected me to a place where I could leave a recorded message for some kind of complaint. This is a written follow up to that.

I worked as a licensed nuclear operator at a sister plant Vermont Yankee for many years and I was in the Navy stationed on a nuclear fast attack submarine. Got fired for raising safety issues at Vermont Yankee in 1992.

Ultimately, my aims are to transform the nuclear regulatory commission. I support the good guys in the plant control room...I think telling the truth is good for our nation and it makes the nuclear industry and a nuclear plant more safe and strong.
 
My name is all over the NRC's Adams document system...I am an expert on their document system.

It would be nice if the Massachusetts joined my petition in some way...gained me some leverage and status over the NRC ...help me gain the documents and information not so far disclosed. I would like Massachusetts and the Attorney General to demand an immediate shutdown of Pilgrim to repair/replace these valves...to demand from the NRC a thorough "special inspection" over these safety relief valves. I discovered the forth new leak from a plant insider. I think this is a generic issue at many plants.

This is a cover-up since the nemo blizzard restart. You have to have $100,000s worth of special nuclear education that gets you to look in the right direction and ask the right question...instead of the NRC and the Pilgrim plant to thoroughly self disclose to a community. It is just not right...it is honesty and integrity! Do you know the difference between state oversight between Massachusetts and Vermont?


Personally, I think the NRC is thumbing their nose at Massachusetts and the Attorney General's office over the recent court relicensing case. We are the top dog here in Massachusetts with a nuclear plant...we can allow Pilgrim to operate in any manner we wish. I am certain the NRC is looking over their shoulder to the nuclear industry with recent events...the states will never have any influence over the safety of a nuclear plant. It is similar to the Vermont Yankee and Vermont state court case. The agency and industry are edgy over this with a lot of money on the line...so they are allowing the Pilgrim Plant to operate outside the lines as a showcase to the industry...show that NRC will always dominate over plant operation even if they are unsafe.

The industry with natural gas fracting, low electric demand and cheap electric grid prices has never been as economically threatened as it is now with declining stock prices and budget cutbacks at the plants. The NRC is totally controlled by the rabid mad dog congressional extreme right wing Republicans. The Nuclear Regulatory commission is in terrible shape.

I grew up in the Pine Point section of Springfield Ma!

Mike Mulligan
Hinsdale, NH
16033368320

Begging Ma Attorney General Coakley

Begging Attorney General Coakley

 
----- Original Message -----
From: ago (AGO)
To: Michael Mulligan
Cc:
Sent: Friday, March 8, 2013 2:07 PM
Subject: RE: Safety Relief Valves at the Pilgrim Nuclear Station

Dear Mr. Mulligan:

Thank you for contacting the Office of Attorney General Martha Coakley. I am writing to acknowledge receipt of a recent message you sent to the Office. Your message has been forwarded to the appropriate division for response. Please note that you may also wish to contact our office directly by telephone at 617-727-2200, and a live operator may be able to direct you. As always we appreciate your patience.

Sincerely,

Constituent Services Coordinator
Public Inquiry &amp; Assistance Center
Office of Attorney General Martha Coakley