John Lubinski
Director, Division of Engineering
Office of Nuclear Reactor Regulation
We described degradation in baffle-former bolts at Indian Point Unit 2 in an April 27 blog post. The degraded bolts were discovered by Entergy, the plant operator, while inspecting the bolts during a refueling outage. Since then, PSEG, the operator of the Salem nuclear power plant in New Jersey, discovered some degraded bolts while inspecting the baffles of Unit 1.
To recap, the bolts hold in place a series of vertical metal plates. Known as baffle plates, they help direct water up through the nuclear fuel assemblies, where it is heated and subsequently used for power production. The baffle plates are attached to eight levels of horizontal plates called baffle-former plates, which are in turn connected to the reactor core barrel.
Because of these findings, the NRC has initiated its process for dealing with emerging issues to evaluate the extent of the problem and determine how best to address it. Here’s what we know so far:
We are confident this issue lacks an immediate safety concern that would lead us to shut down U.S. nuclear power plants or prevent the startup of plants in refueling outages.
We have been aware of the phenomenon. Degraded baffle-former bolts were detected in French reactors in the late 1980s and 1990s, and the NRC published an Information Notice in 1998 alerting the U.S. industry. The higher number of degraded bolts seen recently however, was unexpected.
The 1998 Information Notice prompted several plants to inspect their bolts, and some made adjustments to their baffles or replaced bolts as a result. NRC-approved guidance from the Electric Power Research Institute calls for visual and ultrasonic inspections during a certain period in a reactor’s lifespan. The current inspections at Indian Point and Salem resulted from this operational experience.
It’s important to note that if bolt parts come loose during normal operations and damage fuel, the condition will be detected by routine monitoring of radioactivity in the reactor coolant water. During refueling outages, plant operators look for debris on the bottom of the reactor vessel as another indication of potential issues. Even during an accident, the danger of core damage would be minimal. For these reasons, the NRC does not believe it necessary to shut down any additional plants and order immediate inspections.
Plants with degraded bolts are required to perform analyses and/or replace the damaged bolts before restarting. Missing bolt parts (such as a bolt head) must be accounted for or recovered, or the licensee must perform a “loose-parts evaluation” prior to restarting. The NRC staff will independently assess the root-cause and safety significance of the bolt degradation at each reactor and take appropriate regulatory action.
Indian Point 2 has replaced all of the failed bolts, plus an additional 51 “good” bolts to add additional safety margin. They intend to inspect all the baffle-former bolts again during the next refueling outage.
So how many plants might have this problem? Only Westinghouse-designed pressurized-water reactors with four reactor coolant loops have reported significant bolt degradation. Although there are 29 such plants in the United States, the issue appears to be further limited by two factors: The degraded bolts have all been of a certain type of stainless steel, and they’ve all been in reactors with baffles in a “downflow” configuration, meaning the water entering the reactor is pushed downward between the baffle and the core barrel, which creates more pressure across the plates and stress in the bolts.
There are only seven four-loop Westinghouse reactors at four sites with both the susceptible bolt material and a downflow configuration: Indian Point Units 2 and 3, Salem Units 1 and 2, D.C. Cook Units 1 and 2, and Diablo Canyon Unit 1. (Diablo’s Unit 2 has been reconfigured to an upflow baffle.) Our resident inspectors at D.C. Cook and Diablo Canyon have asked those sites to consider the recent findings and implications for their plants, including their plans for future bolt inspections. D. C. Cook Unit 2 observed 42 degraded bolts in 2010, and as a result replaced 52 bolts. Follow-up visual inspections in 2012 revealed no problems.
Bolt degradation starts to appear sometime after 25 “effective full-power years” of operation (based on actual operation, not calendar years since licensing). So the NRC-approved EPRI guidance advises PWR operators to inspect their baffle-former bolts sometime between 25 and 35 effective full-power years. The NRC requires the inspections as part of aging management plans for reactors with renewed licenses.
As a result of the findings at Indian Point 2, Entergy decided it will conduct detailed ultra-sonic testing of baffle-former bolts in Indian Point 3 during its next outage in spring 2017, instead of March 2019 as previously scheduled. Since Indian Point 3 has operated for a shorter time and has put less thermal stress on its bolts that would cause fatigue, waiting a year is acceptable.
PSEG had been conducting visual inspections every other outage, and because of their discovery of degraded bolts during the current inspection of Salem 1, they decided to conduct the ultrasonic test now rather than in 2023 as previously planned. PG&E indicated to the NRC that it will inspect the bolts on Diablo Canyon 1 during its next scheduled outage in spring 2017.
While the industry is reacting to the recent findings at Indian Point 2 and Salem 1, the NRC will continue to assess baffle-former bolt degradation for any potential implications to the rest of the U.S. commercial reactor fleet.
U.S. NRC Blog 
Mr. Anonymous,
This below is in the Hope Creeks nrc inspection wording.
“increased TS as-found set point margin (from +/- 1 percent to +/- 3 percent) in an attempt to improve Target Rock 2-stage SRV reliability.”
This would be my example of certainty/certainty gaming. Where is the NRC’s proof going from 1% to 3% increases SRV reliability? This is ridiculous. It looks like less regulatory oversight of our financial system will make it sounder and safer. This had no effect on setpoint accuracy. The accuracy setpoint only got worst. This is called a malicious facilitative assumption. It only obscured the decline in SRV setpoint lift reliability. The NRC has finally has disclose to me, this all isn’t in accordance with Hope Creek’s standards and the plant is desperately trying to replace these safety valves.
This would be my example where they are ruining the safety conscience of everyone associated with this lie. They have loosened the setpoint lift accuracy in the hopes of not showing the increasing setpoint unreliability to outsiders. You just have to ask, what would the setpoint lift inaccuracy be if it was still 1%? The setpoint failures, if that is possible, would be much worst today. Just to be clear, all the modifications and bureaucratic sleight of hand has been an abysmal failure to date to fix this problem. It wasn’t done to fix the valve, it was done to con the outsiders. Everything they do only makes the problem worst. It challenges the competence and professionalism of everyone associated it.
They are exaggerating the “certainly” of NRC reporting “the increase of setpoint margin to 3%” is based on increasing safety and reliability. I get the weasely words of the NRC, I am only reporting what the licensees are reporting to the agency. But the agency is reporting about a situation at a plant, don’t they have a responsibility to make sure their words are accurate. To outsiders, everything is always safety safety safety by the NRC, but under the sheets they are secretly reducing the safety margin by a bureaucratic sleight of hand (rules and regulations gaming). Yea, safety/unsafety gaming to outsiders. The breath of this is really an organizational mental illness based on survival. Basically secrecy facilitates this kind of fraud. If all the information was available to outsider with why they went to 3%, the NRC could not say this (secrecy/unsecrecy gaming, transparency/untransparency gaming). These guys are highly educated and extremely experienced. They know what they are doing, or should. By the way, when I was working at a nuclear plant, we all would describe it as playing rulesies.
The NRC would come back to me saying, Mike, how deep with inspections do you what us to go on the technical issues? We are only a sampling agency? This is a really complicated system. We don’t have the resources to do the deep inspections as you want on everything. How about NRC deep/shallow inspection gaming. We just have to (mindlessly) trust the licensees (wink, wink wink). The intentional shallow inspections are facilitating the false NRC statement of “increasing the setpoint testing margin to 3%” is based solely on increasing SRV reliability. Basically the NRC is using governmental credibility to exaggerate the “engineering certainty” with being able to report the increasing set point margin to 3% is based on increasing the safety margin. This all is licensee-NRC collusion to obscure the decline of setpoint lift testing reliability. This all is done is organizational way. I keep saying to everyone, telling the whole truth is important.
The outcome, in a global organizational way with certainty/uncertainty gaming, insiders and outsiders really don’t know the true conditions at these plant. It is global safety culture issues industry wide. They are blinding themselves and us. I get it, this is what congress wants…DEMANDS… the agency to do.
Will these kinds of gaming go on with the Indian Point baffling bolt problems? I think it will.
What happens when we lose USA Governmental credibility over all nuclear industry issues?
Don’t even talk to me about high intelligence/ low intelligence gaming. The educated class and politicians does this all the time when they get into trouble. The “I am so stupid defense” with the highly intelligent professional class in plausible deniability.
I’ll put it in stupid people like me terms. Your car is making a noisy racket while driving. You “fixed it” by putting in expensive ear plugs or scream constantly screaming la la la la…
Can’t you just hear the NRC, you and the NRC has no absolute proof the noisy car is unsafe?
Mike Mulligan
Hinsdale, NH
John writes that if a broken bolt head damaged fuel, it would be detected by increased radioactivity in the reactor coolant system (one of the Performance Indicators in the agency’s Reactor Oversight Process.) That’s an interesting notion, but doesn’t seem to be supported by facts. North Anna Unit 2 experienced damaged to fuel rods so extensive that some fuel pellets got into the reactor water (see the owner’s licensee event report in ADAMS under ML14325A692.) But the reactor coolant system activity Performance Indicator for North Anna Unit 2 did not signal this damage (see http://www.nrc.gov/NRR/OVERSIGHT/ASSESS/NA2/na2_pi.html#BI01). Likewise, PWRs have loose parts monitoring systems (called the Metal Impact Monitoring System at Indian Point) that, in theory, are supposed to warn of broken parts banging around the reactor coolant system. But they don’t. The NRC cannot rely on safety nets that have failed to demonstrate any reliability whatsoever. Such illusions of safety are magic, not sound public policy.
Dear steamshovel : Don’t you see the dishonesty there ? Replacing UT passed inspection, but the licensee wants to replace bolts? Two things are clear here:
1. UT is a farce.(Staff gloat about UT all the time is effective – Merkenzie Bitte!
2. The operator don’t want loose bolts rickety racking in the coolant flow, as I said earlier, that may be the mercy killing of the reactor, Nicht Zehr Gut.
The Huffington Post reports Indian Point ultrasonically tested four bolts and they passed the test. Then they decided to replace the bolts anyway. When they began removing the bolts, the head or body snapped. The UT missed the fatal flaw invalidating all the UT inspection. Did it invalidate other plants who did the UT inspection…they still have large numbers of fatally flawed bolts even given a clean bill of UT health. How does the NRC assure all UT devices can pick up all the flaws in the bolts?
Did you ever hear of engineering certainty/ uncertainty gaming? It is a pernicious form of engineering fraud and corruption in highly complex and technical systems. The extreme complexity and incomprehensible technicality of the systems basically makes these machines sit outside government and community control. Outsiders, law enforcement and the courts don’t have the expertise to understand what is going on. Basically you selectively pick and choose what information to release to outsiders. Organizations who are extremely secretive make certainty/ uncertainty gaming (fraud) undetectable. We live in a world filled with certain/certainty gaming in these days. So you subtly and selectively use engineering certainty and uncertainty to support a self-interest agenda. Basically there is no enforceable code of conduct with the engineering profession.
My position is the rot has to be completely cleaned out. You can no longer trust the UT testing or the NRC to do their jobs. All the bolts, the panels and their support structures need to be completely replaced (or the bolts won’t stay tight to perform their function).
Mike Mulligan equals steamshovel2002
Thanks
Just saying, I was the first person in the USA who made an association with IP’s baffle bolt problem and the water jetting event at North Anna. How in the world can they not be related? And made an official complaint about it to the NY DPS as I don’t trust the NRC.
This might as well may be the Achilles heel of the PWRs. Do you want me believe that this particlar reactor operator will ever replace these bolts ever(They are about shut down a few units, unable to comply with your enforcements/inspection plans). These cold worked and un-annealed hardware will eventually become loose parts inside the core barrel and potentially circulate in the coolant flow.
Face it, 40-years of useful licensed life is accorded precisely taking into account all these contingencies. Let not John bandaid it just for justifying staff action, it is not in safety interest.
“Bolt manufacturers have designed new bolts with a better, more resilient type of steel and slightly modified the shape of the bolts to reduce stress at the bolt head.”
That is a well known scam in the industry, change out cheap components without any proof the change will solve the problem. It is much less expensive than throwing in expensive components and they don’t work. It is just for public consumption. Science is, prove to me the change will make a difference, besides ending up always trusting the profit centered manufacturer. I doubt IP isn’t going to survive another five years. They will come back in the root cause saying in a few outages out they will replace the baffles and bolts and support structure.
The example I thinking about is in Hope Creeks recent inspection report concerning the worsening sticking SRVs. The NRC is answering me in this inspection. They would coat the valve seat and disc repeatedly with exotic precious metals. There is never any proof that the metals would work. They can’t get any manufacturer to make these valves for some reason. Wink! Wink! Wink!.
Here is an example of repeatedly throwing something on the wall hoping to see if something sticks. The testing accuracy setpoint has only gotten worst in recent years with all these modifications. I thought nuclear ethics is you never put something in a core without having proof how it will age throughout the life of the component.
“For example, the industry and PSEG have identified and implemented numerous mitigating strategies including: different pilot disc materials/coatings, addressing critical pilot disc and seat dimensions, correcting methods of insulation installation, and increased TS as-found set point margin (from +/- 1 percent to +/- 3 percent) in an attempt to improve Target Rock 2-stage SRV reliability.
It is a really big deal their analytical computer models can’t predict this kind of damage in the core. What other computer models are just as inaccurate? How about risk perspectives?
Just saying, the NY DPS I was talking too is under corruption federal investigation with Indian Point. Hanky Panky with the governors office. The NY political system is one of the most corrupt in the nation. The governor is under a increasing cloud with bad mouthing IP in the news and simultaneously protecting Indian Point deep inside the political rat holes.
Why not error on the side of safety and do the ultrasonic testing now rather than wait for something to go BAD? Certainly, this should be done no later than the next refueling, since the NRC and their operators have been lucky so far; who needs bolt heads doing any damage?
We understand your skepticism. Look at it this way, however: Because plant operators were aware of the potential for degradation, they knew to inspect their baffle bolts, following the NRC-approved guidance developed by EPRI. Some plant operators modified the configuration of their baffles to lower the stress on the bolts and reduce the potential for degradation. Bolt manufacturers have designed new bolts with a better, more resilient type of steel and slightly modified the shape of the bolts to reduce stress at the bolt head. When Indian Point and Salem replace their damaged bolts, they will use these new and improved models.
David McIntyre, Public Affairs Officer
You guys need to return to being a regulator, instead of a soft sell promoter. And stop using weasel words, they are the basis of lack of regulation. Kind and gentle is not what we ARE PAYING you to do.
Your pay comes from the ratepayers, extracted by the utilities, and then given to you. Its OUR MONEY.
Weasel examples….
So the NRC-approved EPRI guidance advises PWR operators to inspect their baffle-former bolts sometime between 25 and 35 effective full-power years.
We dont want guidance and “advice” we want demands and reports, reports that any citizen can easily inspect online.
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Even during an accident, the danger of core damage would be minimal. For these reasons, the NRC does not believe it necessary to shut down any additional plants and order immediate inspections.
This sounds like a false argument of :limited number of consequences”. In fact, I do believe, that having dozens of rusted bolts and nuts bouncing through a reactor cooling system, is a potential large problem all on its own. They could jam in a valve that is seldom operated, but critical. They could jam in a pump.
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We have been aware of the phenomenon.
This is another false argument I call “familiarity minimization”. Being aware of a problem does not make it less of a problem, and in fact points at your prior non action in IMPLEMENTING mandatory inspections at every outage.
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So the NRC-approved EPRI guidance advises PWR operators to inspect their baffle-former bolts sometime between 25 and 35 effective full-power years. The NRC requires the inspections as part of aging management plans for reactors with renewed licenses.
Really, just one inspection, chosen at the operators convenience, in a ten year period?
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Get back to regulating, we are paying your salary, we are your boss, and WE DEMAND IT.
Visual inspections are not enough !!!
Thanks to a dissenting engineer, visual inspection at IP was supplemented by an ultrasonic test. Unless the recent additional technical testing was performed, mere normal visual inspection that NRC relies on would never have detected the unexpected large number of baffle bolts that were defective, and required replacement !! NRC needs to update, upgrade, and reform agency’s own internal regulatory requirements. This is an ideal example, of how NRC’s processes are insufficient, and fail to provide mandatory levels of system robustness, defense in depth, or anywhere near ‘best practices’. NRC’s history of issuing Notices since 1998, to Licensees about potential risks presented by defective baffle bolts is in itself ‘baffling’ to stakeholders, because it failed to go far enough !!!!
Immediate reform is imperative !!!
Oh, I don’t know, bolt issues. Wow. With degradation of such a basic part after years of knowledge of the potential for problem, what were bolt manufacturers and plant operators thinking on this latest round or were they truly just ignorant – another not good sign.
Hi John, Nice write-up. Frank Costello