NRC Inspectors Head to Indian Point 3’s Electrical Supply Room

33 thoughts on “NRC Inspectors Head to Indian Point 3’s Electrical Supply Room”

1. If You Can’t Identify Errors…
   If you can’t (or won’t) identify errors, how can you learn from them?
   “An error doesn’t become a mistake until you refuse to correct it.”
   Orlando A. Battista
   I am afraid the nuclear industry and the NRC are not learning from their errors and the errors of others in the global nuclear industry.
   Examples:
   • Since Fukushima did not happen in our backyard the US nuclear industry lobbied the NRC hard for ways to only help “mitigate” an accident here not to “prevent” one in the first place. The NRC bought into this strategy as they were convinced that taking such preventative measures would just be too costly for the industry. Thank God these same minds were not at work after the US nuclear disaster at Three Mile Island (TMI). No doubt US nuclear plants were made safer after both prevention and mitigation measures were instituted after TMI in 1979.
   • An important accident mitigation feature now required on all Japanese nuclear plants after Fukushima was dismissed by the US NRC as just not being worth the cost to implement here. This despite the fact that dozens of identical nuclear units like those damaged at Fukushima are operating today in the US.
   • The most serious near-miss nuclear event since Fukushima occurred just last May at the Indian Point Nuclear Station near New York City. Even before investigating this event the NRC concluded that this near-miss was not all that safety significant. I guess flood waters getting anywhere they shouldn’t be in a US nuclear plant is just not the same as flood waters getting into a Japanese nuclear facility.
   Why can’t (or worse yet, won’t) the nuclear industry & today’s NRC take a hard look at their own operations to at least identify areas for improvement?!
   I guess that only our nation’s public health and safety is at risk.
   I am afraid that the viability of the US nuclear industry is job one at the new NRC.

2. It’s Even Worse than I Thought at the NRC
   1. Does how a problem is worded, formatted, or structured make it potentially more serious to the NRC?
   2. Have computers replaced common safety sense at the NRC?
   3. Is the nuclear industry and the NRC becoming more and more tone-deaf to real serious nuclear issues and events?
   I believe the answer is unfortunately yes to all of the above. It is particularly of concern to me since the NRC’s prime mission is supposed to be public health and safety. Let’s take these questions one at a time:
   1. Does how a problem is worded make it potentially more serious to the NRC?
   Answer: Yes.

   Recently I submitted several concerns to the NRC Executive Secretary, the NRC ACRS Liaison, and the NRC Blog site. These concerns were all worded differently but contained the same message. Namely that the NRC failed to thoroughly investigate a near-miss accident at the Indian Point Nuclear Station near New York City. There were several serious safety issues there that were not even discussed let alone cited as violations by the NRC in their special inspection report. But in my latest communication on these same issues I formatted my concerns in NRC “techo-speak”. That is I wrote them just as I believed the NRC should have written these issues up as cited violations of NRC requirements. I was then promptly notified that these apparent violations had been referred to the NRC’s Allegations Division for further review. I was told that if the NRC allegations group decided that they were in fact “allegations” my communication would not be posted on the public NRC Blog site but rather these “allegations” would be handled in a confidential way (translation: secret manner). If the scrubbing of these apparent violations resulted in nothing that constituted an allegation my post would then be made public on the blog. I thought my previous communications to the NRC were quite clear but until I attempted to talk their language they just didn’t seem to get it!

   2. Have computers replaced common safety sense at the NRC?
   Answer: Yes.

   There is a heavy reliance placed on so-called PRA (Probabilistic Risk Analyses) at the NRC. Every single potential problem identified by the NRC at any US nuclear plant is scrubbed by NRC risk analyst experts using these involved analyses with what critics call, “analyses fraught with many assumptions and large uncertainties”. Even before the NRC responded to investigate this Indian Point near-miss, these experts determined through their expert computer analysis that this event was one of the least serious from a set of three possible investigative response options. This type of investigation then only required a team of four NRC inspectors. My concern is how can the NRC conclude potential safety significance ahead of time without knowing all the facts?! And if the PRA folks pencil-whip (I mean analyze) this event as only worthy of the lowest possible investigative response, may that not bias the investigators to perhaps not really look as hard at this event as they otherwise would?!

   And finally,

   3. Is the nuclear industry and the NRC becoming more and more tone-deaf to real serious nuclear issues and events?
   Answer: Yes

   There have been water-intrusion events not only at US nuclear plants over the years but nuclear plants around the globe as well. When flood waters (either from a tsunami or dam break or hurricane rains or from equipment that fails inside a nuclear plant) get into a nuclear plant where they never should be, it is a very serious problem! Even with the painful memories of Japan’s Fukushima still well in our minds this flooding in a vital electrical nerve center of Indian Point was not treated seriously enough in my opinion! In their required report to the NRC, well after this near-miss, Entergy did not even mention this flooding. Even more important this allowed Entergy to be completely silent with regard to any corrective action measures taken and/or planned to prevent a similar event in the future. Also Entergy failed to declare a proper emergency classification as a result of this plant internal flooding. If a proper and higher emergency classification would have been declared many additional resources would have been called out to respond and be at the ready if safety conditions had deteriorated even farther.

   I believe that Entergy failed to properly put public safety first and withheld vital information from the public on this event. Also the NRC failed to properly investigate one of the most safety-significant events since the nuclear plant flooding disaster in Japan.

3. Additional NRC Violations at Indian Point #3 (IP3) Nuclear Power Station
   Additional violations should have been cited at Indian Point Nuclear Station by the NRC.
   I have suggested a write-up for several violations that should have been cited by the NRC (but were not) as a result of the May 9, 2015, serious flooding event at IP3:
   1. 10 CFR 50.9(a) states “Information provided to the Commission by an applicant for a license or by a licensee or information required by statute or by the Commission’s regulations, orders or license conditions to be maintained by the applicant or the licensee shall be complete and accurate in all material respects.”
   Contrary to the above, the Indian Point 2007 license renewal application stated that a water proof door had been installed in a room adjacent to a vital electrical switch-gear room. Our investigation revealed that this water proof door was never installed. The license renewal application also stated that workers flushed the switch-gear room drains every refueling outage. Our investigation into the flooding event at your facility revealed that Entergy had only poured 10 gallons into the drain every two years to check that it disappeared within a minute.
   The failure by Entergy to properly implement these commitments directly contributed to a challenge to reactor, plant personnel, and public safety on May 9, 2015.
   The NRC relies on complete and accurate information submitted by a licensee. Furthermore, as these commitments were submitted under oath and affirmation, further action by the NRC is warranted. The NRC Office of Investigations will be conducting a separate review of this matter as the NRC considers a potential material false statement by Entergy to be a very serious offense.
   2. 10 CFR 50.73 Licensee Event Report (LER) System specifies requirements for licensee submittal of written reports on nuclear power plant events.

   Contrary to the above, the NRC has found that your report submitted to the NRC dated July 7, 2015 was not complete in all material aspects. Specifically, fire protection system flood waters that entered a vital area electrical switch-gear room was not included in your LER report to the Commission. Your report did include preceding events that lead to this flooding but was silent on the flooding of this vital area. The failure to provide such critical information is considered to be a significant oversight on your part. This flooding threatened a vital electrical equipment area in your plant. The loss of this vital equipment would have resulted in a challenge to reactor and public safety.

   The NRC has determined that the submission of an incomplete report, as required by 10 CFR 50.73, is a Severity Level lV violation.

   3. 10 CFR 50.54 (q) Emergency Plans specifies that a licensee maintain and follow an emergency plan.
   Contrary to the above, on May 9, 2015, the Entergy Indian Point Unit #3 Emergency Site Director failed to appropriately classify an actual emergency condition at the site. Specifically, the emergency condition that existed that day should have been classified as an ALERT in strict accordance with the station’s emergency plan. The Emergency Action Level (EAL) for internal plant flooding requires that a threat to vital equipment be classified as an ALERT. The Indian Point Emergency Plan states that this “EAL addresses the effect of plant internal flooding caused by events such as component failures, equipment misalignment, or outage activity mishaps. The inability to access, operate or monitor safety equipment represents an actual or substantial potential degradation of the level of safety of the plant. Flooding as used in this EAL describes a condition where water is entering the room faster than installed equipment is capable of removal, resulting in a rise of water level within the room. Classification of this EAL should not be delayed while corrective actions are being taken to isolate the water source.”
   Instead of classifying this emergency condition at as an ALERT it was classified by the Emergency Director at the lowest event classification of Notification of Unusual Event. This classification error is significant in that had flooding in the vital electrical switch-gear room not be resolved by plant personnel in a timely manner the loss of such vital equipment would have resulted in a significant challenge to reactor and public safety. Classifying this event at the correct ALERT level would have resulted in the immediate activation all licensee on-site and off-site emergency response centers. These significant additional resources would then have been readily available to evaluate and take further correction action as necessary if the safety situation at the plant had continued to deteriorate.
   The NRC has determined that this is a violation of major safety significance and as such has characterized this violation of NRC requirements as a “YELLOW” finding.

   Please consider these as additional violations of NRC requirements at Entergy’s Indian Point Unit #3 Nuclear Station.

4. Nuclear Damage Control

   The NRC stands for the Nuclear Regulatory Commission. The NRC however has become, in my opinion, however, the NIDCC, the Nuclear Industry Damage Control Commission.

   I believe the NRC has become more interested in preserving & protecting the nuclear industry than in preserving & protecting public health and safety.

   The latest example is the NRC investigation of a near-miss accident at the Indian Point Unit #3 (IP3) Nuclear Station, located in the backyard of New York City.

   It appears that Entergy, the owner and operator of IP3, failed to implement a commitment made to the NRC about a decade ago. As part of its 20-year license extension request to the NRC on Indian Point Nuclear Units (IP2 and IP3), Entergy committed to install a water-proof door between a room containing fire protection equipment and a room containing vital plant electrical equipment. It appears this commitment was never honored. On May 9, 2015 water flowed through this door and partially flooded this vital electrical area.

   As with almost any near-miss accident not just one thing has to go south to put reactor and public safety in jeopardy. Two other things went south. These three things resulted, in my opinion, in a very serious nuclear safety near-miss. Anything that threatens the electrical nerve center of a nuclear power plant is very serious indeed. As everyone knows loss of power to nuclear units in Japan lead to nuclear meltdowns.

   So one thing lead to another at IP3 earlier this year. Three different fire protection equipment failures lead to three different sources of flood water in that room containing fire protection equipment. Flooding in this room then lead to flooding in the adjacent vital electrical room through a non-waterproof door. Lastly the drainage system from the vital electrical room was partially obstructed leading to a backup of water on the floor. Operators helped save the day by opening doors to another vital area containing emergency diesel generators to allow flood waters to go from one vital area to another. Operators knew that the diesel generator rooms had sumps and sump pumps to remove any water from a leak there. Fortunately these sumps and sump pumps operated as expected and designed. Sidebar: How comfortable would you be traipsing through water in an electrical switch-gear room?!
   All three things that contributed to this near-miss accident were the result of negligence on the part of Entergy management. First the fire door itself, second the fire protection failures (which were repeats of earlier malfunctions), and finally the partially blocked vital room drainage system (due to inadequate testing of these drains earlier).
   These Entergy management failures directly challenged plant operators (and their personal safety), reactor safety, and public safety.
   The NRC investigation resulted in only one violation when several more should have been cited. I have provided specific examples in previous correspondence.
   This NRC investigation was inadequate. It was aimed at nuclear industry damage control, not an in-depth critical analyses, in my opinion. The investigation also did not identify a significant generic issue that would apply to all US nuclear plants.
   I grew up in the nuclear industry and I felt then that the NRC really put public safety first. Now they are but a shell of their former selves and I believe it is because they have been “captured” by the industry they are supposed to regulate.

5. What is the worst case leak in and around the switchgear room…the worst leak say in a earthquake or corroded fire water pipe system? I count some 3500 to 4000 gallon per minute fire water leak to inundate the safety switchgear room.

   This is the room admitted by the NRC that could shift the plant directly into a safety switchgear explosion and fire…get you immediately into a dreaded blackout.

   This is a total disgrace….

   Thanks,
   Mike Mulligan
   Hinsdale, NH

6. The NRC performed a Special Inspection at the Indian Point Unit 3 nuclear power plant following the failure of a main electrical transformer there on May 9th. The inspection was conducted to review the circumstances surrounding the identification of an accumulation of water on the floor of in a safety-related electrical switchgear room following the transformer failure event. The results were documented in a July 23rd report: http://adamswebsearch.nrc.gov/webSearch2/view?AccessionNumber=ML15204A499.

   Our inspectors determined that the water (measuring less than half an inch) did not adversely affect the safe shutdown of the plant. The water in the room was found to have come from three transformer water deluge (fire-extinguishing) system solenoid valves located in a room adjacent to the switchgear room, which had remained open during the event. Clogged drains caused the water to accumulate and produce minor flooding in the switchgear room.

   The report did contain one “Green” (very low safety significance) Non-Cited Violation. The violation deals with the company’s failure to promptly identify, report and correct a “condition adverse to fire protection.” Specifically, one of the solenoid valves was documented to have opened and not closed as designed during earlier tests of the fire deluge system. This occurred again during the May 9th transformer failure but could have been prevented via earlier repairs.

   The transformer event was also discussed in our second-quarter inspection report for Indian Point. The report contains inspector observations regarding the event (on page 9) and about the transformer replacement outage (on page 17). No inspection findings were identified. That report can be found on our website at: http://adamswebsearch.nrc.gov/webSearch2/view?AccessionNumber=ML15222A186

   Lastly, the NRC is planning a Maintenance Rule inspection of the transformer, and a Problem Identification & Resolution inspection of transformer issues at the plant since 2007, by the end of the year. Those reviews will also be documented in reports, which will be available on our website.

   Neil Sheehan

7. Time is up NRC. Time to give us answers as to what happened at Indian Point 3 back in May. The NRC Special Inspection Report has been issued. This is what your spokesman said last May…

   “That report will be made available to the public via the NRC’s online electronic document system (ADAMS). Until that time, it would be premature for the NRC to comment on what caused the problem and whether the issue should have been identified and fixed previously.”

   Neil Sheehan NRC

   It is no longer premature Mr. Sheehan. Please comment in layman’s terms as to what caused the problem and especially whether this issue should have been identified and fixed previously.

8. Why Only One Violation at Indian Point?
   A serious nuclear near-miss accident occurred at Indian Point Unit #3 (IP3) May 9, 2015. After an NRC team conducted an investigation one violation of NRC requirements was identified. But what do you call the following if they are not also violations of NRC requirements:
   1. What is not providing complete information to the NRC on an incident at a nuclear power plant? Entergy after a month and in a written report did not mention the most safety significant aspect of the May incident-flooding in a vital electrical equipment room at IP3.
   2. What is failing to do something that you said you would do in writing and under oath? Entergy failed to install a waterproof door that would have prevented the flooding that occurred May 9th. Entergy committed to this action as part of its license renewal application to the NRC years before this event.
   3. What is not properly addressing a recurring equipment problem-a problem that actually resulted in uncontrolled leakage from the fire protection system? This resulted in the only cited NRC violation and incredibly the NRC classified this problem as a very minor safety issue-a so-called “green” finding.
   4. What is not taking appropriate action in response to industry operating experience? In this case defective flood barriers at many nuclear plants in the past. If this operating experience had been properly evaluated & corrective action taken by Entergy, the flooding would not have occurred and reactor safety and plant personnel would not have been challenged.
   5. What is not properly classifying an emergency condition at a nuclear power plant? Entergy declared an emergency condition but at the lowest level, a Notification of Unusual Event (NOUE). This event should have been classified at the next higher level, an ALERT. In emergency planning there is a big difference between a NOUE and an ALERT. A NOUE is just what it says, a notification. An ALERT results in complete activation & manning of all incident response centers, Indian Point’s Operations Support Center, Technical Support Center, and its off-site Emergency Operations Center. This brings large emergency response resources to “hot standby” should the emergency condition worsen.
   6. What is not identifying a potential nuclear industry generic safety issue? A couple years prior to this event a flooding walk down inspection was conducted at IP3 as well as at every other nuclear plant in the US. It was conducted in accordance with criteria set forth by the nuclear industry itself and approved by the NRC. This inspection at IP3 did not detect any problems with this non-waterproof door or with the partially-plugged room drainage system in the electrical switchgear room that allowed flood waters to back up threatening safety equipment whose failure could lead to a loss of all power at the plant. The NRC should cite itself for this critical oversight. A proper follow up should be required that examines the adequacy of the generic flood inspection walk down procedure. After appropriate modification all nuclear plants should be required to re-inspect flood protection features that may not have been adequately assessed earlier.
   It is incredible to me that the NRC has not blown the whistle on Entergy. This is being treated as business as usual. Nothing really to see here. Nothing could be farther from the truth! I experienced the old NRC and in a situation like this they would have come down hard reacting to a similar event back then. They would not have been paralyzed by analyses. In fact an NRC Regional Administrator told me after my plant had a serious problem decades ago that “I don’t own this nuclear train, I do not operate or maintain it, but I sure as hell can blow the whistle!” Today’s NRC is a shell of its former self in my opinion. That is not a good thing for reactor or public safety.

9. Unanswered Questions at Indian Point
   I have reviewed the NRC Special Inspection Team (SIT) Report on the water-intrusion event at the Indian Point Nuclear Station Unit #3 (IP3) May 9, 2015. I have also reviewed Entergy’s report to the NRC on the event contained in a Licensee Event Report (LER 2015 004-00) submitted about a month after the incident.
   In my opinion the NRC did a lousy job investigating this near-miss nuclear accident and that Entergy has been less than forthright about it.
   I noted the following:
   1. The Entergy 30-day report failed to even mention the most safety significant aspect of this event-water flooding into a vital area of the plant. This water threatened safety-related electrical switchgear. The loss of this vital equipment would have resulted in a complete loss of all power at the plant. As we know the loss of all power precipitated the disaster at Fukushima in Japan. The Entergy report only discussed a transformer failure and the resulting transformer fire and oil spill. At least the NRC realized the significance of this water-intrusion event and promptly dispatched a team to investigate.
   2. As a result of the fire in the main transformer at the site Entergy did promptly declare an emergency at the site. A so-called NOUE (Notification of Unusual Event) was declared, the lowest of four possible emergency classifications. I could find nothing in the NRC investigative report on whether this classification was the appropriate one. I believe a more appropriate classification would have been an ALERT, the next higher emergency classification. Water flooding a vital area of the plant threatens the operability of the vital equipment therein. My reading of the standard industry Emergency Action Levels (EALs) for nuclear plants requires that a threat to vital equipment be declared an emergency at the ALERT level. The following is taken from a Nuclear Energy Institute (NEI) document on the subject: “EALs address the effect of internal flooding caused by events such as component failures, equipment misalignment, or outage activity mishaps. The inability to access, operate or monitor safety equipment represents an actual or substantial potential degradation of the level of safety of the plant. (Sidebar: Can you imagine how operators must have felt wading through water in a partially-flooded electrical switchgear room to assess this situation?!). Flooding as used in this EAL describes a condition where water is entering the room faster than installed equipment is capable of removal, resulting in a rise of water level within the room. Classification of this EAL should not be delayed while corrective actions are being taken to isolate the water source.” Of course the disturbing part of this is that the NRC team apparently didn’t even look at this important aspect of the event.
   3. The NRC team did specifically identify the source and extent of the flooding in this vital area of the plant. The water came from a malfunctioning component of the automatic fire suppression system that activated to discharge water on the fire on the transformer. The water flowed through a closed door and into a vital electrical equipment area. However the area drainage system was partially plugged allowing water to back up on the floor of the room. The NRC cited Energy with one violation of the lowest safety significance because Energy had not properly addressed identical fire protection problems earlier. There was no mention in the NRC report of why this flooding deficiency was not noted in a “comprehensive” flood walk down inspection done a couple of years earlier by Entergy. A flooding walk down of all potential flood pathways was conducted by Entergy at IP3. Entergy submitted the results of this flooding walk down to the NRC November 27, 2012. Like walk downs required at other US nuclear power plants, these flooding walk downs were conducted in response to lessons learned from the Fukushima flooding disaster in 2010. The IP3 submittal concluded, “Based on the operability determinations, none of the conditions observed during the walk downs were determined to pose a risk to the safe operation of the plant.” Yet, two years after these flooding walk downs, a serious water intrusion event occurs at IP3. This brings into question the adequacy of all such flooding walk downs previously conducted at our US nuclear power plants. After all, this whole industry inspection process and procedure was conducted in accordance with nuclear industry specifications, not in accordance with NRC specifications. And of course those nuclear industry specs were funneled through the Nuclear Energy Institute (NEI) the propaganda and lobbying mouthpiece for the nuclear industry. I am afraid this is just another example of the NRC letting the nuclear industry come up with their own initiatives rather than the NRC setting the requirements. Bottom line: This potential generic safety issue was not flagged by the NRC inspection team.
   4. The NRC SIT report does mention a 2012 NRC inspection report pertaining to potential switchgear flooding on Indian Point’s sister unit, Unit 2. Yet another missed opportunity to detect and correct potential flooding protection problems.
   5. The SIT report mentions that water flowed under the deluge station room door into the switchgear room. The Indian Point 2007 license renewal application stated that a water proof door had been installed in that room to protect the switchgear room. The license renewal application also stated that workers flushed the switchgear room drains every refueling outage. The SIT report only mentions that Entergy had poured 10 gallons into the drain every two years to check that it disappeared within a minute.

   Flood protection measures installed at nuclear power plants in the US and around the world have been notoriously unreliable for many years. To me this “investigation” by the NRC was aimed at “nuclear industry damage control”. The NRC and the ACRS should relook at how investigations are conducted. Whitewash is one term that comes to mind here. Also that the NRC cannot conduct a critical analysis of a nuclear plant incident because they are not truly independent.
   I hope all these issues have been addressed by the NRC but they have not included them in their report. Is there a confidential version of this report within the agency that does?
   Finally, Entergy submitted a grossly deficient report on this near-miss accident. They need to be required to issue a complete supplement to their Licensee Event Report on this incident that addresses the real nuclear safety issue. They also should be required to explain why they completely ignored the most safety significant aspect of this event. This does not build trust in Entergy.
   In fact Energy makes these standard PR boilerplate statements in their report:
   “The event had no significant effect on public health and safety.”
   “There were no significant potential safety consequences of this event.”
   The last statement is especially bothersome. Either Energy did not recognize this event as potentially safety significant or they were less than honest in their report. Either way this event, coupled with persistent problems throughout the entire Entergy nuclear fleet, gives me much concern with respect to public health & safety.

10. Not All Flood Barriers are Created Equal
    Flood barriers installed at our nation’s nuclear power plants (NPPs) have been notoriously unreliable. The latest case involved those “barriers” that failed to keep water out of an electrical switchgear room at the Indian Point NPP. This despite the fact that these barriers had, just a couple of years earlier, been inspected for adequacy by the owner and operator of the plant, Entergy.
    Furthermore, over many years numerous problems with these barriers have been experienced at a number of US NPPs and at a number of NPPs around the world.
    Seems like the nuclear industry and the NRC simply cannot solve this generic and critical reactor safety issue.
    “Mucking out” after a flood is a time-consuming and labor-intensive process. But “mucking out” after a nuclear plant flood would be impossible. Why? Because a flood at a nuclear power plant can result in a Fukushima-type disaster.
    Why has it been so hard for the nuclear industry and the NRC to solve this persistent problem?
    Facts:
    • There are scores of flood barrier penetrations at each of our NPPs.
    • There have been scores of such penetrations that have been found to be defective over the years.
    • There have been several formal NRC Information Notices sent to each US NPP alerting them of these potential problems.
    • There have been special flood barrier inspections, like the one recently completed at Indian Point NPP, conducted at all US NPPs.
    • There have been a number of actual water-intrusion events at NPPs here in the US and around the world.
    Questions:
    • Considering the dire potential consequences of NPP water-intrusion events, why hasn’t the industry and the NRC been much more aggressive in wrestling these problems to the ground?!
    • Why are NPPs being allowed to operate with such a serious, unresolved, generic nuclear safety issue?
    • Are any flood barriers at our NPPs subject to a so-called single failure? That is, can the failure of a single flood barrier (permanent or temporary, fixed or installed when a flood is anticipated) result in,
    o The loss of a SSC (Safety System Component)?
    o The loss of an entire redundant train of safety equipment?
    o The loss of an entire safety system? Or,
    o The common-mode failure of all AC and DC power at any NPP?
    • For any flood barriers whose failure can result in threats to safety-related equipment,
    o What compensatory measures have been taken?
    o What design changes (modifications) have been completed to those especially susceptible barriers?
    o What more adequate & frequent inspections have been undertaken to catch any subsequent problems with such barriers?
    o What has been done to institutionally flag these barriers (placards, warning signs, etc.) so that the critical nature they serve is obvious to all? This would be similar, for example, to other warning signs in the plant like this door is a fire barrier and must remain closed when not in use.

    Not all flood barriers are created equal. Some protect property and some protect not only property but reactor and public safety as well. It is high time for public safety to be job 1!

11. Dr. Bill Corcoran made this statement in a article he wrote about the 13 characteristics of a world class corrective action program…
    “Organizations that optimize their learning from experience will outperform those that do not. Those that do not are digging their own graves by making it easier for their competition.”
    Clearly, this is exactly the characteristic that the nuclear industry and the NRC are dropping the ball on. Nuclear power lost the competitive edge long ago but now it seems they are losing the safety edge as well. Only the public will suffer if this nuclear nonsense continues!

12. Good questions Dr Bill that I wish I knew the answers too. But here is the link to the walk down report…pbadupws.nrc.gov/docs/ML1235/ML12354A311.pdf. Sorry Dr Bill but I can’t seem to get this link to work. I found it by googling, “Indian Point Unit 3 flood walkdown report”.
    Dr. Bill, aren’t you one that’s the expert on corrective action programs among other things?
    I would love to get my hands on copies of the plant’s corrective action documents that pertain to this 2012 flood walkdown at IP3. Especially of interest would be their assessments of the safety significance and consequences of each of the flood protection and mitigation features found to be substandard. Their corrective actions to prevent recurrence would also be of interest. I think though that the outcome, if the NRC really digs into this properly, will be that the flood barriers that failed at IP3 were either overlooked (not examined) or that the inspection technique used was inadequate to assess operability. After all, this whole inspection process and procedure was conducted in accordance with nuclear industry specifications, not in accordance with NRC specifications. And of course those nuke industry specs were funneled through the Nuclear Energy Institute (NEI) the propaganda and lobbying mouthpiece for the industry. I am afraid this is just another example of the NRC letting the nuke industry come up with their own initiatives rather than the NRC setting the requirements like it should be.

13. Our Special Inspection focusing on this issue is still in progress. The team left the site last Friday but is still waiting for more information from the company. Once the inspectors have all of the information they need, they will conclude that phase of the review and inform the company on a high level regarding their findings. The team will then have 45 days to issue a report containing its findings. That report will be made available to the public via the NRC’s online electronic document system (ADAMS). Until that time, it would be premature for the NRC to comment on what caused the problem and whether the issue should have been identified and fixed previously.
    Neil Sheehan

14. Slayer,

    How long had the failed barrier been non-compliant?

    Can you tick off just a few of the assessment and inspection activities that had to have been ineffective for this to occur?

    Would you be so kind as to post a link to the walk down information?

15. This IP3 Near Miss Accident Should Never Have Happened
    Two years prior to this flooding incident at IP3, an extensive flooding walk down of all flood penetration pathways was conducted by Entergy and IP3. Entergy submitted the results of this flooding walk down to the NRC November 27, 2012.
    Like walk downs required at other US nuclear power plants, these walk downs were conducted in response to lessons learned from the Fukushima flooding disaster in 2010.
    The IP3 flooding walk down report noted the following:
    “…a total of 65 walk down packages of features credited for flood protection” were included in the flooding walk downs.
    The IP3 submittal concluded, “Based on the operability determinations, none of the conditions observed during the walk downs were determined to pose a risk to the safe operation of the plant.”
    Yet, two years after these flooding walk downs, a serious water intrusion event occurs at IP3.
    Brings into question the adequacy of all such flooding walk downs at our US nuclear power plants.

16. Neil, thanks for letting us know about the main XFMR and just how long it will drag out this investigation. But the elephant in the room is the near miss common-mode failure in the vital switchgear room and you know it! Not since the Brown’s Ferry fire, TMI, and the Fukushima flooding has any event so threatened reactor and public safety as this IP event. High time for the NRC to talk w a straight tongue!

17. NRC inspectors are continuing to review the recent transformer failure at Indian Point 3. Until those inspections are completed, we would not be able to answer the question of whether this failure could have been anticipated and/or prevented.

    When will the RCE for this one be posted? We cannot provide an exact timeframe at this point. A key reason is that Entergy will have to have completed a diagnostic examination of the transformer to determine the failure mechanism, and those assessments can be time-intensive.

    Neil Sheehan

18. Common-Mode Failure
    Flooding at Fukushima caused a common-mode failure. Recently, flooding at the Indian Point Nuclear Station near New York City nearly caused a common-mode failure.
    Flooding or a fire can take “out all the redundant systems needed to cool the reactor cores, the systems needed to keep the containments from overheating and leaking, and the systems needed to help predict the path and extent of the radioactive plumes. At Browns Ferry (located in Alabama), workers managed to employ ad hoc measures in time to prevent a disaster. At Fukushima time ran out.”
    Excerpt from the book Fukushima by Dave Lochbaum continues…”Defense in depth is both a blessing and a curse. It allows many things to go wrong before a nuclear plant disaster occurs. But when too many problems arise or a common-mode failure disables many systems, defense in depth can topple like a row of dominoes. The risk of common-mode failure can be reduced through enhancing defense in depth, but it can never be eliminated. The true curse of defense in depth is that it has fostered complacency. The existence of multiple layers of defense has excused inattention to weaknesses in each individual layer, increasing the vulnerability to common-mode failure.”
    Let’s hope the near-miss common-mode failure at Indian Point lights a fire under the NRC and the nuclear industry, for the common-good!

19. The RCE for the 2010 similar event is at

    Click to access ML12088A511.pdf

    How come we needed another event?

    When will the RCE for this one be posted?

20. Sooo, basically we got four special inspections going on in Entergy plants right now. Two at River Bend, one at Pilgrim and another one at Indian Point.

    I think the real culprit is “nothing-ever-matters risk regulations. It is really sneaky deregulation. The cumulative result of regulations by a Republican campaign right now is deregulation on steroids. Basically the Republican House and Senate are blackmailing a USA regulatory agency…reduce NRC cumulative regulations or we will drastically cut the agency’s budget.

    The punishment of a violation or repeated violation through risk perspective is not enough incentive to make straight the organization. You are just mildly paper whipping bad actors with copious minor or not cited violations. I think the agency is worried about massive retaliatory budget cutting…

    Risk Perspectives was always massive deregulation dressed up as science and engineering…It was a result of runaway campaign contributions and the humongous influence of the utility industry with the politicians.

    I wish we had a similar size, influence, unlimited money and political reach as the Electric Utilities…an organization who could contest the Electric Utilities and nuclear industry. We just don’t have it. We are all worst for it.

    Mike Mulligan
    Hinsdale, NH

21. How many decades have the flood barriers been non-compliant at IPEC? At ANO? Elsewhere in U.S. NPPs?

    Click to access ML14279A268.pdf

    Where was QA? Where was Reg Affairs? Where was the CNRB? Where was INPO? What was the effectiveness of OE? What was the effectiveness of RCA?

    Is this the best we can do?

22. Great comments all.

    The NRC should have outside inspectors conduct an immediate fire seal inspection of all penetrations at every NPP, and post the findings, my guess is that at least 15% will have issues that should be “fixed”, but they have not been done because they are of low importance to plant operators.

    The NRC needs to be far more proactive in their inspections, especially since on-site NRC inspectors are not finding these issues until AFTER a problem is discovered.

23. Thank you so much for your reply. I wish your inspection goes well and will wait for a 45 days report.

24. The focus of the Special Inspection Team will be on the presence of water in an electrical switchgear room at Indian Point 3 amid the transformer failure event on May 9th. However, the NRC Resident Inspectors assigned to Indian Point will continue to follow up on the main transformer failure event on May 9th and related issues. Once the Special Inspection Team formally concludes its reviews, its members will have 45 days to issue a report containing its findings.

    The exact cause of the fire is not yet known. A post-failure examination of the transformer should yield information on the cause(s). The NRC will be reviewing the results of that examination and documenting that information in an upcoming inspection report.

    Neil Sheehan

25. Everything Seems to Be a No Never Mind to Today’s NRC
    Please, Mr Moderator, bear with me, I will eventually have no trouble tying this blog to Indian Point. Just let me set the stage a little first.
    Today’s NRC is a shadow of its former self, in my opinion. The old NRC that I knew decades ago was a tough, no-nonsense, regulator. I know because I was on the receiving end of their “tough love”! As a manager at a small nuclear power plant (about half the capacity of most nuke plants operating today) I got in trouble w the feds over a couple of incidents in my nuclear plant. (There were undoubtedly more but I have chosen to ignore them, HA!) Both of these incidents were far less serious than a number of the incidents that have happened at nuclear facilities in recent years. Back then I was hammered by the NRC. The NRC Regional Administrator at the time said to me, “I don’t owe your plant; I don’t operate or maintain it; but I sure as hell know how to blow the whistle!” My opinion is that today’s NRC doesn’t even know where the whistle is. Looking back, over the years since I retired, I have reluctantly admitted to myself that I deserved the regulatory dress-down that I got at the time. My small plant and small utility were assessed civil penalties by the NRC in both cases. In recent years, due to incidents and violations at my plant, my utility has formally turned over the keys to operating the plant to a large nuclear operating company. The keys were also turned over to a large nuclear operating company at another facility in the state owned by a different, small electric utility. Their regulatory track record merited this action as well. I feel that both these moves were wise. Large nuclear operating companies have large technical and monetary resources that can quickly be brought to bear as needed to support their plants and resolve issues there. There is though a significant downside to a large nuclear operating company, like the one operating the Indian Point nuclear units. To put it bluntly, they are in bed with the NRC. They enjoy a beneficial symbiotic relationship with the NRC. One hand washes the other. There is a revolving door between these large nuclear operating companies and the NRC; folks are utility employees one day and NRC employees the next; and vice versa.
    No wonder then that the NRC seems to never get very excited about any problem or incident that occurs at plants operated by the big nuclear outfits.
    Entergy operates several nuclear plants, among them Pilgrim, Arkansas Nuclear, and Indian Point.
    I find it very disturbing that significant events have occurred at each of these Entergy plants and these incidents have been treated lightly by the NRC.
    Pilgrim has experienced many automatic reactor shutdowns over the years and even partial and complete losses of AC power at the site. An NRC Commission Chairwoman, even before the latest loss of offsite power event occurred at Pilgrim, thought that Pilgrim should be shut down and subject to an enhanced NRC inspection program if problems continue. No such additional oversight or action has resulted.
    ANO, a couple of years ago, found numerous degraded flood barrier penetrations at the site. Degraded flood barriers had been found earlier at other nuclear power plants and were the subject of several NRC Information notices sent to all nuclear plant owners to warn them of the potential problems.
    Now Indian Point Unit #3 has actual water intrusion through faulty room flood penetration barriers. Obviously Entergy did not learn from the experience at their own plant (ANO) and they didn’t even appropriately respond to this potential safety issue when notified formally by the NRC years earlier?!
    I am dismayed by the totally unacceptable performance by both Entergy and the NRC. Flooding, either the external type or the internal type, at a nuclear facility is one of the most serious events that can occur. Flooding is known in the industry as a common mode failure. Flooding wipes out redundant power supplies and equipment, just like it did at Fukushima. It makes no difference whether the water comes from Mother Nature or from faulty or ruptured equipment at the site itself, the result still can be devastating.
    Will this finally get the NRC concerned enough to really hammer Entergy?!
    Will this dangerous near miss get the NRC to not only inform the industry of this generic and repetitive problem, but to actually require the industry to check for and take all necessary actions to ensure that flood protection measures at each of our nuclear facilities are adequate and meet all design requirements?
    The NRC needs to develop a spine and really start putting public safety first!

26. Excellent comments by my blogging partners!
    Thought I would share this little note that I sent to the NY Governor…
    Subject: “Dangerous Near Miss at Indian Point Nuclear Power Plant Unit #3” or “How We Almost Lost NYC”
    Dear Honorable Governor Andrew M. Cuomo:
    Included below is a recent blog update by the NRC of an incident at Indian Point Unit #3 located near New York City. (Not included in this blog for an obvious reason).
    At a nuclear plant, either too much water or too little water can be dangerous.
    A recent water intrusion event at Indian Point nearly caused a loss of vital electrical equipment required to safely cool nuclear fuel at the site. What the NRC Blog does not include is just how close water got to this vital equipment. A reliable source of mine stated that water came within inches of this equipment. Specifically I was told that the water level rose to within two inches of this vital electrical switchgear. The NRC does acknowledge the water intrusion event but indicated only that there was “an inch or two of water on the electrical equipment room floor”.
    As we are all well aware, the loss of power to vital reactor cooling equipment can soon lead to the a disaster like Fukushima.
    The NRC has arranged for a special investigation of this incident. I hope all the really hard questions are asked by this team. For example…
    • Why were the flood protection barriers to this vital room inadequate?
    • There have been a number of flood barrier deficiencies found at US nuclear power plants over the years. Fort Calhoun Nuclear Station and ANO have found numerous deficiencies in flood protection barriers at their facilities. The NRC has issued NRC Information Notices to all plants regarding these potentially generic problems. What measures did Entergy take to ensure these vulnerabilities did not pose a safety threat at Indian Point?
    • Considering how close IP3 appears to have come to a catastrophic accident, why is the NRC not requiring an Augmented Inspection Team (AIT) or even an Incident Inspection Team (IIT) be sent to the site instead of its lowest level of investigative response, a Special Investigation (SI)?
    • Although IP3 will be out of service for some time due to the loss of its main transformer by fire during this event, why hasn’t the NRC ordered the plant to remain shut down in cold condition until not only the NRC investigation is completed but until all necessary corrective measures have been taken?
    • Why hasn’t IP2 been shut down until it can be checked for similar vulnerabilities?

27. I would like to see the following points;
    -What topics, other than water on the floor, dose Special Inspection Team investigate for 45 days?
    -Dose NRC already know the cause of the fire?

28. This threatens nuclear power as a non-GHG source. What can we do?

29. I think the Independent National Transportation and Safety Board did a wonderful job at explaining the tragic crash of the Amtrak Philadelphia commuter train. I’d give them an “A” plus.

    I do miss NTSB chairperson Deborah Hersman’s pretty face and especially her ability to communicate.

    Hmmm, the NTSB is missing a commissioner just like the NRC?

    As I said earlier, if Indian point and the NRC did a proper 50.59 and License Amendment Request (LAR)…the replacement of nonflammable PCB coolant to flammable vegetable oil coolant…they would have hardened the area around the transformer expecting a big vegetable oil fire and tremendous amounts of fire hose water being used.

    Published on May 18 at 12:45 pm:

    http://steamshovel2002.blogspot.com/2015/05/indian-point-needs-new-yard-loop-fire.html

    “Indian Point Needs New Yard Loop Fire System and Distribution Piping”

    My guesses are:

    1) A leaking fire water system piping or component.

    2) The copious fire hose water leaked down outside of the concrete foundation and then entered though a concrete foundation crack into the power supply room. Are there many concrete foundation cracks in IP buildings? The fire fighters must have directed copious hose water protecting the turbine building siding. Was there damage to the siding?

    3) The siding was damaged by the fire…that is how the water got into the power room?

    4) The overflowing transformer holding tank backed up into the supply room if both connected to each other. Does the supply room have a drain and where does it go?

    Did the NRC shame Gov. Cuomo by not telling him about supply room water on the floor or did the Governor intentionally withhold the water leak in the said electrical room from the public for some reason? Why didn’t the Governor disclose the water on the floor? The information was big deal heading into a special inspection.

    Bet you the equipment operator has to inspect that room every four to eight hours.

    Mike Mulligan
    Hinsdale, NH

30. Absolutely Dr Bill! As pointed out by others, our own USA nuclear power plant experiences over the years with degraded flood protection barriers should have caused industry-wide inspections and corrective action to improve these barriers. Fort Calhoun and ANO are other plants that I recall having similar problems. Obviously sharing industry experience is important, but what is critical is that action is taken to check for and correct problems at other plants based on knowing about industry problems. This is more of the same old stuff and that is just plain inexcusable!

31. The NRC issued a “white” (low to moderate safety significance) inspection finding on April 17, 2014, for the issue involving cable penetrations at the Ginna nuclear power plant: http://pbadupws.nrc.gov/docs/ML1410/ML14107A080.pdf . An NRC Supplemental Inspection was performed to review the plant owner’s evaluations and corrective actions in response to the finding. The results of the inspection were contained in an inspection report issued on Sept. 30, 2014:
    http://adamswebsearch.nrc.gov/webSearch2/view?AccessionNumber=ML14273A035 . The inspection team found that the company’s actions, including sealing the penetrations, were satisfactory. That led to the closure of the issue.

    The NRC’s focus is on plant safety rather than the cost. As such, we do not have a figure on the cost for the corrective actions.

    Neil Sheehan

    Moderator Note: Future comments unrelated to Indian Point will be moved to the Open Forum section of the blog.

32. What did Ginna finally do to rectify the river water overflow impacting the DG start batteries through an open hole into the battery room from a manhole. What was the fix, and what was the cost.

    Its kind of on topic, with the Indian point water, and the fact that Fukushima emergency equipment was flooded, causing the ongoing triple meltdown/out

33. Should the post-Fukushima flood barrier upgrades have prevented this?

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