ML20203D180

Discusses Safety Concern,Inaccurate LERs & Accurate Plant Internal Documents.Lists Some Troubles from New Insp 98-13

ML20203D180
Person / Time
Site:	Vermont Yankee
Issue date:	01/10/1999
From:	Mulligan M AFFILIATION NOT ASSIGNED
To:	Victor Dricks NRC
Shared Package
ML20203D173	List: ML20203D169 ML20203D180 ML20203D198
References
NUDOCS 9902160057
Download: ML20203D180 (4)

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[Tcjuan Carter - Safety conc.m: Inaccurate LERS c.nd accurate pLnt intirtti documents: Whose Truth.

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. From: " Michael Mulligan" <m.mu!Iigan@worldnet.att. net > '

To: " Victor Dricks" <VLD@nrc gov >, "Raymond shadis" <s...

Date: Sun, Jan 10,199910:23 PM

Subject:

Safety Concem: Inaccurate LERS and accurate plant intemal documents: Whose Truth.

Mr Dncks I l

Guys: I Here are some troubling things from the new inspection 98-13:

6 They are talking about an inspection that assures quality in a device that is used for public radiation protection and safety. There has been other l

LER's of recent with the MSIVS conceming excessive leakage- that out of 8 valves 4 leaked, - that you have 4 huge steam lines with two valves on each line- that at one point out of 4 lines,2 of the lines leaked excessively-for a line to leak it means that two valves in a row must leak. As a credible radiation barrier there is just an obscene numbers of failures in i

the primary containment system.

'l think leak-rate testing failure of the MSIVs just after the shutdown initiated this maintenance activity that the NRC totally mis-charactorizes.

The story should go: becruse of the obscene number of MSIV failures during leak-rate testing caused by tim uG!ty's inadequate prior maintenance or lack of , W was force to perform unscheduled maintenance on the valves finding a defect in one of them which needed a weld job, then an inspection i was forgotten, . . is this just a technicalinfraction as the NRC portrays it or an astounding amount of mistakes on a public radiation protection safety device? Is the problem isolated or characterize a systemic breakdown?

Are we looking at a problem utility or a safety agency which fails to

_ perceive of a widespread degradation in plant safety? Can the NRC see!

Translation of the below: After the repair they had a inspection which they i forgot to perform as defined in the QA manual. In the first LER that W generatcd on this, they portrayed it as discovering the missed inspection after the startup. It should be noted that to perform the inspection-W .

would have had to shutdown, depressurize, disassemble the valve which would l have taken a week. You see the consequence of a screw-up has become life-threatening -impacting capacity factor. And when it came to the NRC l attention, they could have ordered W to shutdown and perform the inspection at any time.

During this inspection (98-13) the NRC asked the participants what actually happened. They discovered W knew about the missed inspection prior to the startup, if W didn't know what the right thing to do in their hearts, they knew if they asked the NRC what should we do about the missed inspection, the NRC would have made them do it. This would have delayed the startup for

, many days. So they started the plant up then falsifed the LER.

4 Th3 NRC asked W what was the justification for filing the late and

! misleading document. W said in the administrative game of NRC paper-work,

! that only when the MSIV has the potential to be a safety device does it

reach the point of keying it into submitting a LER. In other words, once the plant exceeds 212 degrees or making steam did they have to start the 9902160007 990205 PDR ADOCK 05000271

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- [Taju n Carter - S=wy Car,cem: Inaccurate LERS r_nd accurate plant int; mal documents: Whose Truth ge 2 paperwork process. It just so happens to fall that if they got caught, the l ability of the govemment to charge the plant with falsifying paperwork has been reduce to nothing. So W had in its mind that an inspection wasn't performed, that a re-inspection would be very costly, that after the startup the event would be seen a insignificant and not worthy as shutdown issue, 3

that they didn't have to initiate the paperwork until after the startup thus alerting the regulators. Even worst they could revise the historical record implying the discovery occurred after the startup.

The nrtural process of consequences with meaning have been subverted. If W paid the price of doing the inspechon before the plant startup, they would have spent money on their own to prevent the next screw-up. Maybe the industry realizes that they are so close to the limits of viability that they have invoked the concept of utility " goodwill". It's the govemmental expectation that a utility can break a regulation without permission with I very little consequence if it is in the name of capacity factor. In the end W knew that it paid to go into the crap-shoot of the govemment regulators.

It's what all that rate-payer money went to influence the politicians that controlled the regulators. It's how the game of these privileged people work. That the rule breaking will be characterized in the end as a minor infraction which protects the govemment regulators from the spe:ial interest and the public. This is symbolic of the two tiered govemmental access where the public safety has become subservient to the favored it is  ;

me expectation that Jane Doe must not lie to a grand ju'y but if a utility

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gets caught in a lie, the consequences will be inconsequential They are '

assassinating the conscience of their employees.

More fundamental to democracy is the ability of the utility to hide there problems in the private documents. These utilities can portray a situation one way in the public documents while another way in the intamal documents, it's like the company having two sets of books. Within his LER the public is never let in that the utility is having broadbased problems administrating the plant Quality Assurance program (ASME Sechon XI repair / replacement program).

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The federal system is design to look at problems in there isolation only, no '

wonder problem plants still pop out of nowhere. Notice the NRC doesn't even l

question the confusion with the ASME and QA program because the NRC is  !

confused with all the interfaces with ASME and quality anyway. Ask some of ,

the NRC inspectors how conclusive is the individual plant ASME plans are.

l mike

b. Observations and Findings During the 1998 refueling outage, W identified two flew indications in the body of main steam isolation valve (MS!V) V2-80B. The indications were ground out and the affected areas were restored by weld repair. The repairs were inspected by magnetic particle and radiographic examination. Following reassembly, the valve was stroke tested satisfactorily and was subject to normal operating pressure during the reactor pressure vessel operational system leakage test. Subsequently, W identified that a visual (VT-3) '

examination of the repairs had not been performed as required by secbon XI of the ASME code. Technical specification 4.6.E requires that inservice

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[Tajuan Carter - Safety Concern

Inaccurate LERS and accurate plant intema! documents: Whose Truth.

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,- inspections be performed in accordance with this code.

l The LER inoicated that the root cause of this event was omission of relevant information from the plant procedure that provides general guidelines and instructions for maintenance activities on safety related valves. Corrective action consisted of a revision to that procedure, OP-5201," Safety System Va!ves " to include the VT-3 pre-service incetion requirement. However, the root cause analysis that was generated as a .esult of the W event report indicated that the root cause was inadequate work control process.

Specifically, the requirement to perform the pre-service VT-3 inspection (contained in procedure YA-VT-11) was included in the work order only by reference to the applicable procedure, rather than being included as a step within the detailed work instructions. In addition to the corrective action specified in the LER, the ER root cause analysis indicated that an ASME Section XI repair / replacement program would be developed to provide guidance and direction on required code repairs and inspections.

In addition, the inspector noted that the event date (May 28) was prior to plant startup from the refueling outage (June 1). At the time of discovery, the plant was in cold shutdown and had been since before work on the MSIV had commenced. Therefore, the valve had not yet been required to perform any safety function, and, had the issue been resolved prior to startup, no violation of the code or TS would have occurred. However, this aspect of the event was not addressed in the LER. After discussions with maintenance management, W initiated an investigation of this issue. Pending completion of W's investigation, this issue remains unresolved. (URI 98-13-02: ASME Pre-service Inspection of MSIV Not Resolved Prior to Plant Startup)

The inspector concluded that LER 98-18-00 was weak, in that the root cause did not identify problems with the disposition of the ASME Code inspection or W's apparent decision to restart the plant prior to resolving the issue, which caused the TS violation described by the LER. These findings were discussed with W management. W initiated ER 98 20B4 to investigate these issues, and W's plant manager stated that a supplemental LER will be issued. The inspector considered W's response to this issue appropriate and a final determination regarding potential violations of TS requirements for ASME Code implementation, or adequacy of corrective actions required by 10 CFR 50 Appendix B, will be evaluated during review of the unresolved item identified above. Therefore, LER 98-018-00 is closed.

c. Conclusions l

[Tejuan Carter - Safety Concern: Inaccur_te LERS and t ccurate pl:nt int; mal documents: Whosa Truth.

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Weaknesses in VY's disposition of a missed ASME Code inspection were not identified during the licensee's root cause investigation. These problems were identrfied during an NRC review and followup inspection associated with  ;

Licensee Event Report (LER) 98-018-00. VY has initiated an Event Report to investigate and assess the previous corrective actions. An unresolved item l has been opened pending additionalinformation from the licensee and a supplement to the LER.

For your benefit MR Dricks I sent this to you on around 9/16/98.

Dear Mr. Dricks.

This is in response to your 9/14 message conceming me being unfocused. If you will remember the time before the NRC shutdown of the Millstone complex.

l The point when the whistleblowers had given up on the site management, when they were reporting the safety concems directly to the NRC. From what perspective did the agency see things? Did the agency see a top notch organization from the past, with Millstone, excusing many of the emerging j problems of the site. Or did the agency see the events as prediction on all j

the damage that site would inflect on the surrounding area and the industry.

Does the sun revolve around the agency or does the NRC occupy just a small part of the electrical distribution system? Can I see the truth only when its documented from three different sources or from the wisp in the air.

Whose truth cares more about the future.

Two LER'S, one from Vermont Yankee and the other from Pilgrim are a concem I to me.

LER 98-009 from Vermont Yankee incident occurred 980321 conceming 4 MSIVS LER 97-025 from Pilgrim occurred 971123 conceming 2 MSIVs

Having these 6 MSIV failures occurring in such a short time frame, less than l four months, seems very strange to me. I've looked at nudocs on MSIV failures for the last 10 years for VY and I've seen nothing like it. Same for Pilgrim with their failures. These failures stand out from the recent history of MSIV problems. Why?

Conclusion:

Regional problem, in that utilities allow these nuclear grade safety components to degrade until operational problems to show up. That

, the utilities don't know what overhaul cycle or testing, will be needed to j prevent equipment problems. That during refueling they just don't ever have

' enough time to do a complete overhaul. I am worrying that this is a just an emerging nuclear safety equipment trend. mike mulligan i