Victor Dricks
Senior Public Affairs Officer
Region IV
The Arkansas Nuclear One power plant, in Russellville, Ark., is coming under increased NRC focus as a result of flood protection problems.
Beginning in 2013, Entergy Operations officials and the NRC began extensive inspections of the flood protection program at ANO. Many problems were discovered and are described in a Sept. 9, 2014, NRC inspection report.
All told, more than 100 previously unknown flood barrier deficiencies creating flooding pathways into the site’s two auxiliary buildings were found. These included defective floor seals, flooding barriers that were designed, but never installed, and seals that had deteriorated over time. In one case, a special hatch that was supposed to be close a ventilation duct in the Unit 1 auxiliary building in the event of flooding had never been installed.
In the unlikely event of extreme flooding – a kind not seen since weather records have been kept for the area – significant amounts of water could have entered the auxiliary buildings. This could have submerged vital plant equipment, as well as the emergency diesel generator fuel vaults. The licensee has replaced degraded seals, installed new flood barriers and adopted new measures to better protect the site from flooding.
NRC held a regulatory conference with Entergy officials on Oct. 28, 2014. After considering information provided by the company, NRC determined violations related to flood protection have substantial safety significance, or are “yellow.” (The NRC evaluates regulatory performance at nuclear plants with a color coded process that classifies inspection findings as green, white, yellow or red, in order of increasing safety significance.)
The NRC divides plants into five performance categories, or columns on its Action Matrix. ANO Units 1 and 2 received yellow violations in June 2014 because electrical equipment damaged during an industrial incident increased risk to the plant. Workers were moving a 525-ton component out of the plant’s turbine building when a temporary lifting rig collapsed on March 13, 2013, damaging plant equipment. Those violations moved both units from Column 1 to Column 3 of the NRC’s Action Matrix. The agency increases its oversight of plants as performance declines.
The new violations will lead NRC to reassess whether even more inspection resources need to be focused on ANO. The NRC will determine the appropriate level of agency oversight and notify Entergy officials of that decision in a separate letter.
U.S. NRC Blog 
This is the most recent analysis.
Moderator
Victor,
Would you be so kind as to provide a link to a more forthcoming root cause analysis than then one linked here?
Click to access ML13213A270.pdf
Quotation: “An organization that has demonstrated an inability to find its own problems has demonstrated its own incompetence.”-Bill Corcoran
There is no link to an NRC document containing a root cause analysis for the flooding deficiencies at ANO. NRC inspectors reviewed a root cause analysis prepared by the licensee, but we do not possess a copy of this document. You will need to ask Entergy for this. This is a link to the NRC inspection report identifying the preliminary yellow findings associated with flooding deficiencies. It contains a brief statement regarding the licensee’s root cause analysis:
http://adamswebsearch.nrc.gov/webSearch2/view?AccessionNumber=ML14253A122
Our review of the root cause and of its corrective actions are contained in the preliminary yellow finding and in the Inspection Procedure 95003. (http://www.nrc.gov/docs/ML1616/ML16161B279.pdf)
Section 4.2 discusses specifics that were reviewed and items that the NRC is continuing to follow.
Victor Dricks
Victor,
Thanks ever so much for the effort you put into this blog.
I have another question.
The blog said:
“All told, more than 100 previously unknown flood barrier deficiencies creating flooding pathways into the site’s two auxiliary buildings were found. These included defective floor seals, flooding barriers that were designed, but never installed, and seals that had deteriorated over time. In one case, a special hatch that was supposed to be close a ventilation duct in the Unit 1 auxiliary building in the event of flooding had never been installed.”
Is there a link to a root cause analysis of any or all of these safety deficiencies?
Is there a link to an NRC inspection report that evaluates the root cause analyses?
• Problem Age/Longevity
An inescapable fact is that old long-existing problems got to be old because they were not effectively addressed when younger. The harm got to be as old as it was because neither the harm nor the elements of its causation were addressed when the harm was less old.
The time extent of a problem can be referred to as its age, its longevity, its persistence, its survival, or the like.
Observation: Problems do not mellow with age.
Observation: In 1999 a damning report on “medical error” was released . In 2016 an even more damning report on “medical error” was released .
Observation: After the Fukushima Explosions and Meltdowns numerous flood barrier deficiencies that had existed for decades were found in nuclear power plants.
Observation: The Open Phase Condition problem existed since the first U.S. nuclear plant was designed.
Observation: When problems are not resolved at the rate they emerge their cumulative adverse synergism mushrooms into certain disaster.
Observation: Problems often survive multiple reviews, government inspections, management change-outs, ownership transfers, and scrubs by legions of hired experts.
Observation: A problem does not go away when it is officially called by another name. The NRC calls some of its unresolved problems “Generic Issues.”
Quotation: The beginning of wisdom is to call things by their right names.”-Confucius
Observation: Time wounds all heels.
Quotation: “A stitch in time saves nine.”
Observation: The causation of the crash of the 2006 RAF Nimrod XV230 Maritime Reconnaissance Aircraft included vulnerabilities that had existed since the Falklands War in 1982.
Mr. Dricks,
You posted:
___________________________________________________________
The NRC found that the engineering and maintenance organizations at Arkansas Nuclear One missed opportunities to identify the flood barrier deficiencies, and that the management oversight of the engineering and maintenance organizations was insufficient to ensure that a thorough evaluation of flood barrier deficiencies was conducted prior to the stator drop event.
_________________________________________________________
Where can I find a list of these missed opportunities?
What were the harmfully noncompliant conditions, behaviors, actions, and inactions that resulted in each of the missed opportunities?
What are the extents of those harmfully noncompliant conditions, behaviors, actions, and inactions that resulted in each of the missed opportunities?
This one reminds us of the Renaissance observation:
“…in the beginning of the malady it is easy to cure but difficult to detect, but in the course of time, not having been either detected or treated in the beginning, it becomes easy to detect but difficult to cure.”
Nicolo Macchiavelli
“The Prince”
Chapter III
Thank you again for your response.
You stated: “The blog is a place where the public can post their opinions.” – and seemingly suggested that my other concern would be best directed to staff working the ANO project.
My interest remains entirely with the extent to which this blog represents a source of substantive stakeholder engagement rather than a communications control exercise which devolves into, “The NRC broadcasts and the public ‘opines.'” Such an outcome would be a step backward in Openness.
This channel is open as a matter of public policy initiative taken by the elected officials at the highest level of Executive government. It employs methods and affordances which are considerably more flexible than the processes NRC has long used to manage its transactions with non-licensee stakeholders. That likely results in both improvements and other outcomes less obviously so.
We are all in a discovery mode here; in your internal discussions please challenge your own assumptions about what good value is before there is a fulsome body and some evident patterns of experience with using this channel. I know this is a difficult ask; as a taxpayer I need to make that ask.
One thing that kind of “discover and develop” type of Openness (long an NRC core value) would look like just now, is to recognize when a thread opens an opportunistic moment. Opportunistic that would be for informed, non-licensee persons in the public to use an ROP topic, seemingly specific from the perspective of Region IV, as a case study to explore more general implications of how regulation is serving the public interest.
In such a circumstance, it seems entirely appropriate, when these thread generalize to “pass the buck” to someone in HQ. I’m content to accept some NRC Regional line management discretion in that regard so long as the election is made specific; at this point I wouldn’t need any elaborate basis for a specific decision – its the pattern of engagement over a range of “possibles” that will lead to a sense of what the full range of these blogs are good for. Because we adopt an exploring and pioneering mode with these high-speed big data channels, the attributes of effective exchange are necessarily uncertain; we can all give ourselves permission to Do by Learning.
Those who have been commenting here know what they are talking about; we are valued sources of feedback unencumbered by all the safeguards in the formal comment process. We all value the extraordinary extents to which NRC has long maintained an open and transparent public record of its workings – we value to the work to improve the automation of such public access and to expand discourse such as this. It is from our own prior investment that we take the stance of being a demanding customer for your efforts.
Despite our occasional grumpiness, we are not anti-nuclear and definitely not anti-regulation. We’ve been discussing these topics on line for more than five years in several LinkedIn and other public forums. Frankly, the official voice of NRC input (and others such as INPO and NEI) has been rather sparse in those channels. I presume but do not know, how NRC leadership views participation in or even tracking of such public discourse as part of staff’s professional performance expectation; I would like to understand that – even if the policy is a work-in-progress. The days of tidy, government facilitated community engagement are gone.
In summary, when I asked a general question, you pointed me in a specific direction – one likely intended to move this thread to closure. We all can do better. Compared to oversight of offshore drilling or fracking, the NRC provides the most sophisticated “learning laboratory” within which to explore, from the engaged public’s side, how to take more responsibility for assurance of effective and proportionate regulation (e.g. assurance of adequate budget given the 90% recovery by fee provision – a topic in active discussion on LinkedIn right now). Many channels resulting in bandwidth parity are essential to that.
OBTW, with two Yellows, I’m not worried about ANO’s supervision.
Bill M
I’m still looking for an analysis of the harmful conditions, behaviors, actions, and inactions that made it take forty years to get attention to the flood barrier defects.
BillM —
Again, our apologies for the linking issue.
The blog is a place where the public can post their opinions. If you wish to have a direct conversation with NRC staff related to ANO, please use this email address: opa4.resource@nrc.gov
Moderator
Please see the links posted in the Moderator comment of 2/9.
Moderator
Thank you for providing public accessible links.
Looking at the previous versions it’s quite clear; “https” indicates a secure (password protected) server. It has nothing to do with cutting and pasting or WordPress. We in the public need for someone in your role to be well-versed in such things.
Do you or any colleague intend to reply to my other critique of your earlier comments?
Thank you, Bill M
These documents are all public in our ADAMS system. It’s unclear why the original links did not work. We’ve substituted alternative URLs. It’s possible you may need to cut and paste the URL directly into your browser due to WordPress issues related to links in blog comments.
Unit 1 CALC-ANO1-CS-12-00003, “Flooding Walkdown Submittal Report for Resolution of Fukushima Near-Term Task Force Recommendation 2.3: Flooding, ADAMS ACCESSION NO: ML12334A009, 11/19/2012 http://pbadupws.nrc.gov/docs/ML1233/ML12334A009.pdf
Calc 32 – 9207374 – 000 , “Title Arkansas Nuclear One Flooding Hazard Re-Evaluation – Probable Maximum Precipitation”, ADAMS ACCESSION NO. ML14307A911, Date: 4/30/2014 http://pbadupws.nrc.gov/docs/ML1430/ML14307A911.pdf
Revised Response to NRC 10 CFR 50.54(f) Request for Information Regarding Near-Term Task Force (NTTF) Recommendation 2.3, Flooding Arkansas Nuclear One – Units 1 and 2 ADAMS ACCESSION NO. ML14120A494, Date 5/30/14 http://pbadupws.nrc.gov/docs/ML1412/ML14120A494.pdf
Attachment 1 to OCAN051402 Arkansas Nuclear One, Unit I (ANO-1) Revised Flooding Walkdown Report ADAMS ACCESSION NO. ML14139A380, Date 5/14/14 http://pbadupws.nrc.gov/docs/ML1413/ML14139A380.pdf
OCAN051402 Arkansas Nuclear One, Unit 2 (ANO-2) Revised Flooding Walkdown Report ADAMS ACCESSION NO. ML14139A381, Date: 5/14/14 http://pbadupws.nrc.gov/docs/ML1413/ML14139A381.pdf
Data Request Supporting United States Army Corps of Engineers (USACE) Flood Analysis Arkansas Nuclear One – Units 1 and 2, ADAMS ACCESSION NO. ML14262A083, Date: September 9, 2014 http://pbadupws.nrc.gov/docs/ML1426/ML14262A083.pdf
Moderator
This episode is about more than flood barriers.
It is about forty years of insufficient competency, integrity, compliance, and transparency.
Fixing the flood barriers is pruning the poison ivy.
What are the conditions, behaviors, actions, and inactions that resulted in forty years of insufficient competency, integrity, compliance, and transparency.?
Where is the licensee’s analysis of this?
Mr. Dricks,
I applaud your impulse to share the detailed event related documents; I’m surprised that you didn’t recognize that the hyperlinks you provided are behind the Agency firewall and not available to those of us in the public.
I wish to contest one aspect of your earlier response. While the licensee is directly, and acutely accountable for achieving the level of safety anticipated when the NRC approved the license; they are not ultimately responsible. Surely the massive public consequences of Fukushima point out that regulatory ineffectiveness is what ultimately precipitates early deaths and lives disrupted.
The ROP is sometimes going to put NRC in a position to be the second to know a significant deficiency exists, that does not lower its accountability to the public. It is simply implausible and unacceptable that NRC not understand that it, as the approval authority under the Atomic Energy Act, is in no way less accountable than the licensee.
Any routine quality verification program for an enterprise as complex as an NPP license must rely upon a systematic sampling approach backed up by a graded expansion of oversight when significant issues arise. However, because of the lag time likely in some instances such as this with the flooding protection, the licensee should be facing very painful economic sanctions when a major problem cascade unfolds such as the instance at ANO.
I could make the case how ineffectively the NRC treated ANO and how the inspectors and all the management are insufficiently trained on using force and coercion in order to get a change in behavior from an individual or organizations…this created the Pilgrim Juno event.
By the way, I can make the case as the Vermont Yankee crisis was developing; the Pilgrim troubles were drastically intensifying. In a protective response by the agency, they yanked away inspection services fearing the credibility issues with VY would spill over to Pilgrim. They feared the VY issue would threaten Pilgrim, and highlight the inadequacy of Entergy fleet wide. Here are the issues that prove the NRC withheld inspection services and gamed the Pilgrim report card.
The NRC gave a pathetic inspection response to the new leaking SRV/ADS valves ( I call all of them inop from 2011 till present) and the Juno LOOP. The Nemo LOOP was much worst with repeated LOOPs cause by different issues…it was characterize as a full loop. It got minimal inspection interest in the next cycle and no focused or special inspection. The Juno LOOP is characterized a partial LOOP, no repeated LOOPs in subsequent days. The Nemo LOOP deserved a special inspection considering the pathetic history of problems in the switchyard and the inadequate designed 345 lines supporting plant operation. Going into Nemo, they were in power restriction based on leaking and inop SRV valves…you would be disgusted with a timeline on the all the problems they had with these new valves. iI is unbelievable the agency didn’t cause a full focused inspection or special inspection over these safety valves. It is like the NRC blatantly didn’t cover the prolonged SRV problems and potential common mode failures of the SRVs in the normal inspection cycle, as the Vermont Yankee plant was collasping? Now in Juno we got a mysterious failure of SRV valve to open when called and I bet it was leaking related
Just as Vermont Yankee was collapsing, the NRC was yanking away typical inspection services from Pilgrim in order to protect Entergy. They were giving Pilgrim a better report card grade than they deserved by not performing required inspections and withholding boots on the ground resources that would disclose the true conditions of the plant.
One the Vermont Yankee existential crisis was finalized with a plant shutdown…the NRC comes back with a rather comprehensive report on the reliability of the Pilgrim switchyard and it 345 supporting lines. This is how a competent cover-up are done at this time. When the crisis is over, the culprits disclose harmlessly their own sins. It better than someone later calling it a cover-up…it neutralized in the future a much large possible cover-up crisis.
Mr Dricks did you just provide a reason or an excuse for the NRC not finding problems that don’t just jump out and grab an inspector?! Licensees have to pay you guys close to $200/hour for these inadequate inspectors and inspections. These “difficult-to-find” flood barrier problems were identified by the Fort Calhoun Nuclear Station as recently as 2011. Flood barrier problems were identified well before that and documented in NRC Information Notices. Aren’t you getting tired of making excuses for the NRC?!
The NRC reviews the designs of nuclear plants to ensure they meet rigorous engineering standards and once those designs are approved, depends on its licensees to build plants as designed. Prior to authorizing fuel loading and commercial operation, the NRC conducts extensive inspections of a plant’s major systems, structures and components. This inspection effort continues once the plant begins commercial operation and is conducted by resident inspectors who are assigned to each facility, as well as specialists from our Regional and Headquarters offices. The average nuclear plant receives about 6,600 hours of direct inspection annually. Inspection, by its nature, is a sampling process that by design, focuses on issues most important to safety. The deficiencies in flood barrier protection escaped detection by NRC inspectors because they were not readily visible. They involved floor seals that appeared intact but were not watertight, cracks in areas of structures that were not accessible to inspectors and flood barriers like hatches in ventilation shafts, that were called for in designs, but never installed.
Victor Dricks
I think a more plausible risk would be the worst accident possible along the path of the travels with stator…from the turbine to the equipment hatch. The worst concrete floor punctures with the stator.
I see one photograph just feet from the fallen stator…right on its fatal path…where there is a tremendously large cable run. As example, what if the stator landed on all those cables and started a big fire? What is the worst possible accident capable over that?
It is common for these event…the floor being designed for the worst possible accident. Say dropping from the highest rig elivation…how about a fall from giant overhead crane.
10CFR50, App B, Criterion II says:
Controlled conditions include the use of appropriate equipment; suitable environmental conditions for accomplishing the activity, such as adequate cleanness; and assurance that all prerequisites for the given activity have been satisfied.
Is verifying that the plant was built right a prerequisite for loading fuel? for going critical? for operating at power?
Yes. The NRC found that the engineering and maintenance organizations at Arkansas Nuclear One missed opportunities to identify the flood barrier deficiencies, and that the management oversight of the engineering and maintenance organizations was insufficient to ensure that a thorough evaluation of flood barrier deficiencies was conducted prior to the stator drop event.
Yes. The authorities and duties of persons and organizations is delineated in the licensee’s safety analysis report (e.g., chapter 12), the administrative controls section of the plant’s technical specifications and in ANO’s Quality Assurance Manual.
Victor Dricks
10CFR50, Appendix B, QA Criteria, Criterion I states, in part:
The authority and duties of persons and organizations performing activities affecting the safety-related functions of structures, systems, and components shall be clearly established and delineated in writing.
Did the NRC identify each of the persons and organizations that missed the earlier, better, cheaper, safer opportunities to identify the flood barrier deficiencies without needing to have the fatal stator drop to reveal flooding that should have been blocked by failed barrier?.
Were the authority and duties of persons and organizations performing activities affecting the safety-related functions of structures, systems, and components clearly established and delineated in writing, as required?
I was able to find an active link to the Unit One revised walk down report.
Click to access ML14279A268.pdf
Victor,
How come the first walk downs didn’t find the nonconformities?
Thanks.
Victor,
None of those links worked for me.
I’ll try searching.
I appreciate your efforts even thought the links don’t work.
Thanks, Victor.
President Reagan’s approach was:
Trust, but verify.
The approach in this case was:
Trust and justify.
Big difference?
What was the breakdown of responsibility?
The licensee is ultimately responsible for the safe operation and maintenance of the facility, including compliance with applicable regulatory requirements, in order to protect public health and safety. This also includes implementing a quality assurance program that complies with the requirements of 10 CFR Part 50, Appendix B. The identified deficiencies represented the licensee’s failure to design, construct, and maintain certain flood protection features of the facility. The NRC has an oversight program that includes inspections that are conducted on a sampling basis. In this case, neither the licensee’s processes nor the NRC’s previous inspections identified these deficiencies until further focused reviews were performed by both the licensee and the NRC following the March 2013 Unit 1 stator drop event.
How come it wasn’t noticed?
When these type of safety significant issues are discovered, the licensee is required to perform an in-depth evaluation of the issue to determine the cause(s) of how/why the performance deficiencies and degraded conditions occurred. This evaluation also includes how the identified cause(s) potentially affect other aspects of plant equipment and operation, and what is needed to be done to prevent recurrence of the issues. This evaluation is currently being conducted by Entergy. The NRC will conduct a supplemental inspection to determine the adequacy of the licensee’s evaluation, which will include an independent assessment of the extent of the risk significant issues. Through this supplemental inspection, the NRC will ensure that reasons why the deficiencies occurred are identified and addressed. The results of this inspection will be publicly available in an NRC inspection report.
Does the insufficiency of compliance still exist?
Corrective actions have been taken to address all deficiencies that have been identified related to flood protection. The NRC has conducted inspections to verify the implementation of these corrective actions. The NRC will also conduct additional supplemental inspections to provide additional assurance that the root causes for these issues have been identified and appropriately addressed by the licensee, including strengthening licensee programs to ensure that any other potential deficiencies will be identified and corrected, and that no new deficiencies will be created.
Victor Dricks
10CFR50, App B, Criterion I says:
…The applicant may delegate to others, such as contractors, agents, or consultants, the work of establishing and executing the quality assurance program, or any part thereof, but shall retain responsibility for the quality assurance program…
If the applicant/licensee had effectively done this the plant would have been built right.
What was the breakdown of responsibility?
How come it wasn’t noticed?
Does the insufficiency of compliance still exist?
Victor,
Thanks.
Does NRC post its evaluations of such submittals?
As a western hero once said, “Is this all you’ve got?!” I am glad Mr. Dricks that you provided all the links to info to help out Entergy and its “regulator”. Bottom line is that if it were not for the Fukushima accident none of these actions would have been taken to identify long-standing flood barrier protection issues at our power plants. There was lots of our own US of A operational experience that should have resulted in actions long ago to identify these flood protection problems. The NRC and INPO took no decisive action to root this problems out then. Where else has the NRC dropped the ball on known industry safety issues?!
Here are some hyperlinks to Entergy documents related to their reviews of flood protection issues:
Unit 1 CALC-ANO1-CS-12-00003, “Flooding Walkdown Submittal Report for Resolution of Fukushima Near-Term Task Force Recommendation 2.3: Flooding, ADAMS ACCESSION NO: ML12334A009, 11/19/2012 https://adamsxt.nrc.gov/WorkplaceXT/getContent?id=current&vsId=%7BF275856F-215F-454B-A8E5-C79CD3ECEE09%7D&objectStoreName=Main.__.Library&objectType=document
Calc 32 – 9207374 – 000 , “Title Arkansas Nuclear One Flooding Hazard Re-Evaluation – Probable Maximum Precipitation”, ADAMS ACCESSION NO. ML14307A911, Date: 4/30/2014 https://adamsxt.nrc.gov/WorkplaceXT/getContent?id=current&vsId=%7B0BF52538-88DD-4DC2-997B-46F7CE9F3926%7D&objectStoreName=Main.__.Library&objectType=document
Revised Response to NRC 10 CFR 50.54(f) Request for Information Regarding Near-Term Task Force (NTTF) Recommendation 2.3, Flooding Arkansas Nuclear One – Units 1 and 2 ADAMS ACCESSION NO. ML14120A494, Date 5/30/14 https://adamsxt.nrc.gov/WorkplaceXT/getContent?id=current&vsId=%7BC542BA5D-913D-47FA-A481-B36720511AA7%7D&objectStoreName=Main.__.Library&objectType=document
Attachment 1 to OCAN051402 Arkansas Nuclear One, Unit I (ANO-1) Revised Flooding Walkdown Report ADAMS ACCESSION NO. ML14139A380, Date 5/14/14 https://adamsxt.nrc.gov/WorkplaceXT/getContent?id=current&vsId=%7B46C7A0C9-4B3D-4014-8E3E-3A10FA219161%7D&objectStoreName=Main.__.Library&objectType=document
OCAN051402 Arkansas Nuclear One, Unit 2 (ANO-2) Revised Flooding Walkdown Report ADAMS ACCESSION NO. ML14139A381, Date: 5/14/14 https://adamsxt.nrc.gov/WorkplaceXT/getContent?id=current&vsId=%7BD26687BC-888E-4BDC-8D13-CB099FA0BC57%7D&objectStoreName=Main.__.Library&objectType=document
Data Request Supporting United States Army Corps of Engineers (USACE) Flood Analysis Arkansas Nuclear One – Units 1 and 2, ADAMS ACCESSION NO. ML14262A083, Date: September 9, 2014 https://adamsxt.nrc.gov/WorkplaceXT/getContent?id=current&vsId=%7B3E71F7DA-3E2C-4CE6-A5E0-FA20B8EE3C6D%7D&objectStoreName=Main.__.Library&objectType=document
Victor Dricks
Operating a facility that was not built right should be unacceptable-period.
Every manager and oversight person in our industry should view the San Bruno NTSB video.
Have a basin handy.
Are we taking long standing flaws seriously enough?
PPB,
Thanks for your insights.
Could it be that a major issue is barrier integrity?
Harmful stuff gets to intrude and harm the plant?
Harmful stuff gets released to do harm outside the plant?
It’s been an epidemic?
Do we need a nuclear CDC?
Competence?
Integrity?
Compliance?
Transparency?
Which of the four were lacking?
Which of the four could have individually resulted in these problems being prevented entirely and/or caught at the first opportunity?
On the part of the licensee at the plant?
On the part of the licensee at corporate?
On the part of INPO?
On the part of the NRC?
Victor,
Thanks 1.0E+6
Do you have a link to the licensee’s own review?
Thanks for the additional information Mr. Dricks.
I am glad these old flood protection barrier issues at ANO are finally being wrestled to the ground. I just wish these deficiencies had been identified and corrected years earlier. It was noted that flood barrier inadequacies were identified in an NRC Information Notice sent to licensees in 2007. Also “Flooding vulnerabilities due to seal barrier concerns” was also the subject of an NRC OpESS FY2007-02. This 2007 information did not result in actions to find similar deficiencies at the Fort Calhoun Station in late 2010 or at ANO just recently. What other plants are still similarly vulnerable? Is the NRC relying solely on the Fukushima flooding follow-up walk-downs to find all these potential flood barrier vulnerabilities? Also doesn’t the Institute of Nuclear Power Operations (INPO) have an operational experience sharing program that is supposed to promptly alert nuclear power plants to these potential generic issues? However, informaion notices have no teeth. It is still true apparently, even in the nuclear industry, that you can lead a horse to water but you cannot make it drink. I am sure the best run nuclear plants act in a timely & responsible manner when given a heads-up on potential problems. These plants are obviously not among them!
The scope of the Fukushima walkdowns performed by the licensee’s contractor did not include several passive components and structural features for the Unit 1 and Unit 2 auxiliary buildings, and the licensee did not effectively monitor this this effort. The stator drop in March 2013 revealed deficiencies in the licensee’s assessment of flood protection barriers. NRC inspectors determined that the licensee failed to properly identify all of the flood protection features as specified in the NRC endorsed guidance, NEI 12-07, “Guidelines for Performing Walkdowns of Plant Protection Features.” When identified, the licensee re-performed the reviews of essential flood protection features, identified additional features that were not initially identified, and provided an updated response to the NRC regarding what they found subsequent to their initial response to the 50.54(f) letter. Following the stator drop event, the NRC conducted an Augmented Inspection Team (AIT) inspection to determine how the accident occurred and identify possible violations of NRC regulations. Some flooding related deficiencies were identified in the AIT report issued in June 2013. By this time, the licensee had begun its own review of flooding related deficiencies. The licensee had already fixed some problems that had been identified, but was also continuing to identify other problems. The AIT follow up report exited in February 2014, but kept the flooding issue open. Entergy’s review continued through March 2014, at which time the licensee believed that all the deficiencies had been identified, repaired, and that the underlying root causes had been addressed. In May 2014, the licensee documented the results of their final walk downs in a letter to the NRC.
In June 2014, the NRC issued two yellow findings for the stator drop, while work was continuing on NRC’s review of the flooding-related issues that had been identified by both the NRC and the licensee. This review included a complicated significance determination process that involved an evaluation of probable maximum precipitation and flood probabilities. In August 2014, the NRC’s inspection of these issues was completed, and the results were communicated to the licensee in an exit meeting. In September 2014, the NRC issued an inspection report detailing the flood protection deficiencies and identifying preliminary yellow violations. A regulatory conference was held with Entergy officials in October 2014, during which the licensee presented a number of complex hydrologic evaluations in an effort to estimate the frequency of a flooding event at ANO, as well as several proposed strategies for recovering safety functions during such an event. NRC review of this information was necessary in order to determine the safety significance of the issue, including evaluation of the precipitation and flooding model methodologies as well as inspections to assess the licensee’s proposed recovery strategies. The risk significance of the flooding issues was finalized on January 22, 2015, with the issuance of two yellow findings.
Victor Dricks
Here is a quotation from NRC Information Notice 2015-01:
______________________________
On March 31, 2013, following the collapse of a temporary lifting rig carrying the Unit 1 main turbine generator stator, a rupture in the fire water system resulted in water leakage past floor plugs in the auxiliary building and subsequent accumulation of water inflow in the safety-related decay heat removal room B through a room drain pipe.
This event overlapped the timeframe in which the licensee was assessing flood mitigation features in response to Fukushima-related orders issued by the NRC.
The extent of condition reviews by the licensee related to this event and those discrepancies identified during flood mitigation response efforts found numerous other pathways that were not effectively sealed against flooding in the auxiliary building and emergency diesel fuel storage buildings. These conditions were not identified during the licensee’s initial flooding walkdowns in accordance with NEI 12-07.
_________________________________________
How come it took such a tragedy to find that the plant had not been built right?
Extent?
Causation of extent?
Where is the licensee’s investigation report?
The current loss of offsite power frequency used in the agency’s risk models is slightly less than 3 events per 100 years.
Victor Dricks
Watchdog groups?
Where is the evidence of their effectiveness and integrity?
Ancient plains aboriginal wisdom was, “When you notice that the horse you are riding is dead, dismount.”
Great Comment.
+
I think the answer should be in the millions of dollars for each violation and the money donated to the local watchdog groups so that they can better provide (think well funded) true watch dog functions that would also keep the NRC on its toes…
That would really help improved reactor safety in the USA.
Timely Sharing of Nuclear Plant Operating Experience Still Lacking
It is noted that beginning in 2013, ANO Company and NRC officials began extensive inspections of flood protection barriers at ANO as a result of a follow-up to the Fukushima accident in Japan. Many flood protection barrier deficiencies were found. The NRC determined that a YELLOW finding was appropriate due the substantial importance of these problems to nuclear safety.
Several years earlier at the Fort Calhoun Nuclear Station (FCS) the NRC determined that a YELLOW finding existed there as flood protection procedures were found to be inadequate. In the follow-up to this finding the licensee found many flood barrier deficiencies at FCS and reported same to the NRC in a licensee event report. Some of these deficiencies had existed unknown to the licensee since 1985!
My concern is why identical-type problems show up at another US nuclear plant several years later?
It does not appear that a key lesson was learned from the TMI accident over 35 years earlier. That lesson is that plant operational experience should be promptly shared with other nuclear power plants.
Who dropped the ball?
As a result of the many flood barrier deficiencies identified in 2010 by FCS was any timely communication (of any sort) made of this significant operating experience to any other nuclear power plants by the NRC? OR
Does the NRC expect licensees to do this on their own through their own plant operating experience groups?
Since the NRC abolished the AEOD in the late ‘90s could the lack of a centralized clearinghouse for operational experience data have contributed to not discovering significant flood protection problems at ANO until they were discovered by a separate initiative following the Fukushima disaster?
Competence?
Integrity?
Compliance?
Transparency?
Which of the four were lacking?
Which of the four could have individually resulted in these problems being prevented entirely and/or caught at the first opportunity?
On the part of the licensee at the plant?
On the part of the licensee at corporate?
On the part of INPO?
On the part of the NRC?
What are the similarities and differences from Davis-Besse 2002?
Did the licensee provide an investigation report to the NRC?
Did it address the above?
http://steamshovel2002.blogspot.com/
“It’s got to be noted, as you go down the emergency operating procedures the complexity massively increases and they increasingly depend on less quality components and procedures. My take is as you go down the emergency operating procedures the quality should increase because risk is increasing. Complexity and uncertainty levels just skyrockets as you increasingly depend on not fully designed and engineered systems and procedures. At some level of complexity and stress, an outcome can never be assured. As the accident strips massively the redundant safety systems away from the plant, the consequence of a error drastically increase the risk of damaging the core. I hate add on systems or components because usually they aren’t fully tested and all the uncertainties aren’t fully washed out. I like a holistically designed plant…all these components in on plant first design.
The NRC take on these cooling paths to be valid should be, you have to demonstrate flow up to the first containment isolation valve. If you depend on service water flow or temporally diesel generator, then you have to demonstrate flow up to the first containment isolation valve and you measure flow and pressure. Make believe flow paths are not approved. You really need periodic, yearly or every two years…the troops getting on the ground and pressurizing the alignment up to the first isolation valve to be even considered as a safety system.
Basically in this day and age, a double fail safe, push a button and the system aligns and fills up and SG level is controlled…
This at ANO is basically the Fukushima dilemma…not having a diesel generator 100 feet up the ocean bluff and hard wired to the plant. The philosophy with the Japanese in a Tsunami, of having to fight the battle to save the plant in the flood waters within the plant.
So how about a big tank way outside the flood zone. It hard piped into the plant right up to the steam generators. Starting the diesel generator, push a button and open up a valve or two…everyone safe. An access road to the tank…with the fire department cycling their trucks in a out to fill the tank. You could have constructed a sturdy cement cauldron out in the river and hard piped to near this tank. Then a fire truck could continuously fill the tank from the river.
Then the other Japanese dilemma…would you damage the steam generators in order to cool the core?
I didn’t hear anything about the flex system coming in to save Entergy’s butt?”
Mike Mulligan
Hinsdale, NH
So why isn’t the NRC recalculating the so call electrical yellow finding violation. It seems the flooding yellow finding components were active just prior to first yellow finding. Two cases:
1) A ANO stator electrical yellow finding with the flooding barriers all according to regulations.
2) A ANO stator electrical yellow finding with the flooding barriers according to an inadequate flooding barriers in this second ANO yellow finding.
Once can legitimately surmise the second example (example 2) contains a lot more risk than the first example and justified a lot bigger violation than a yellew.
This would be mycontention that the disposition of risk perspectives is riddled with fraud and corruption.
The flooding issue is another example with inspector activities and the ROP..the system is severely inadequate to knowing the true conditions at a power plant…the NRC selectively enforces tech specs and the licensing conditions at these power Plants. Why isn’t it a slam dunk that ANO employees are going to jail? Why isn’t there some serious soul searching going on in the NRC with why their inspection and inspector activities didn’t undercover these violation at the first opportunity many years and decades ago?
*I am looking for this answer: What is the generic “Loss of offsite power” accident rate used in all NRC risk calculation and within coming up with a plant violation level? I am told it is 2, 3 or 5 LOOPs per 100 years. Could the answer be in the once per hundred year terms?
Mike Mulligan
Hinsdale, NH