Braidwood & Byron - Samuel Miranda response to the NRC's withdrawal of RIS 2005-29

Samuel Miranda is a former U.S. Nuclear Regulatory Commission official:

From: Samuel Miranda
Date: Sat, Oct 26, 2019 at 2:31 PM
Subject: My response to the NRC's withdrawal of RIS 2005-29

For your information:

On May 15, 2019, the NRC withdrew a Regulatory Issue Summary, RIS 2005-29 (1), and referred to (2) for supporting information (i.e., its reasons for withdrawal). This information is in an NRC memorandum from Eric R. Oesterle to Mirela Gavrilas, entitled, “Supporting Information for Staff Recommendations in Response to Executive Director for Operations Tasking in September 15, 2016, Exelon Backfit Appeal Decision.” The memorandum (2) is dated September 6, 2017, and recorded under ADAMS Accession No. ML17237C035. 

The withdrawal memorandum responds to the Executive Director for Operations Tasking with an important rejection of the Executive Director's claim that the pressurizer safety valves can be relied upon, consistently, to relieve water without fail. The withdrawal memorandum (1) supports the rejection with the results of several valve tests that indicate the valves will be damaged if they relieve water. (They're designed for steam relief only.)  This means that no licensee can assert a water relief capabilty for these valves. That is, no licensee except Exelon. See (4) and (5) for details.

Significantly, (2) is not available to the public. It seems that the NRC staff withdrew a Regulatory Issue Summary, RIS 2005-29, a guidance document that had been publically available since 2005; but withheld its reasons for doing so. Consequently, I filed a FOIA request, NRC-2019-000363 (3), to have [2] released. The NRC responded with a redacted copy (4) of (2). The response (4) lists 19 staff positions in RIS 2005-29 and draft Revision 1, and completely redacts 18 of them. The NRC invoked the deliberative process privilege (FOIA Exemption 5, which is specified in 5 U.S.C. 552(b) (5)), to justify the redactions.

Yesterday, I filed a lengthy appeal to the NRC's FOIA response. (5)

Here is a brief timeline of these events.

 Date                     Event Description and Reference

  5/15/2019         NRC withdraws RIS 2005-29, and Draft Revision 1, “Anticipated Transients That Could Develop Into More Serious Events” (1) (ADAMS No. ML19121A534).

  7/18/2019         I filed a FOIA Request for the NRC's non-public memorandum which is cited as ADAMS No. ML17237C035. (2) The FOIA Request is designated NRC-2019-000363. (3)

  9/20/2019         NRC responds to FOIA Request, NRC-2019-000363 with ADAMS No. ML19266A445 (4), a redacted version of the requested memo, ADAMS No. ML17237C035. (2) 

 10/25/2019       I filed an appeal regarding the NRC's response to FOIA Request, NRC 2019-000363. The appeal is designated NRC-2020-000026. (5)

If you devote the time and effort it takes to sort through the attachments, then I expect you’ll have lots of questions.

I look forward to answering them.

Sincerely,

Sam Miranda, PE [Professional Engineer]

Yet more regulatory rollback at Perry

Perry - Facility Changes, Tests and Experiments

Perry modifications / regulation rollback 

ML19280C628

https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML19280C628 

Document Title:	Perry Nuclear Power Plant - Report of Facility Changes, Tests, and Experiments
Document Type:	Letter Operating Report
Document Date:	10/07/2019

Perry atomic reactor suffers latest safety mishap, as ratepayer bailouts keeps it afloat for years to come!

Perry License Event Report - Loss of Safety Function

ML19277G666

https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML19277G666

Document Title:	LER 2019-004-00 for Perry Nuclear Power Plant, Loss of Feedwater Heating Results in Loss of Safety Function
Document Type:	Letter Licensee Event Report (LER)
Document Date:	10/04/2019

NRC rubber-stamps yet another safety regulation roll back at the dangerously age-degraded Davis-Besse, Ohio atomic reactor

Davis-Besse - Containment Leakage Rate Test Interval Request

ML19273A113

https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML19273A113

Document Title:	2019/09/27 NRR E-mail Capture - Davis-Besse Nuclear Power Station - Acceptance of License Amendment Request to Extend Containment Leakage Rate Test Interval (EPID: L-2019-LLA-0186)
Document Type:	E-Mail
Document Date:	09/27/2019

Torus Coating Problem at Fermi Unit 2, Monroe County, MI

July 17, 2019 power point presentation by David Lochbaum, formerly with the Union of Concerned Scientists (UCS).

Feb. 2007 report "Futility at the Utiliy," also by Lochbaum and about Fermi 2.

Here is a note from David Lochbaum to Michael Keegan of the Coalition for a Nuclear-Free Great Lakes, and Don't Waste Michigan, in Monroe, MI, dated July 17, 2019:

Hello Michael:

I did some research into the history of the torus coatings matter at Fermi Unit 2. 

Attached is a PDF of the results of that inquiry. Feel free to forward to any one who desire.

My research did not reveal why this problem exists at this late date. It was allegedly solved two decades ago. And over the past 20 years, there have been many -- MANY -- reminders to industry and NRC about potential problems with the alleged solutions. 

And yet is remains a problem without a certified solution. 

And for this problem to lack a solution at this plant is even more amazing. More than a decade ago, I authored the attached report about another safety problem at Fermi 2 that the owner and the NRC allowed to exist for two decades. 

It would appear that in Michigan, the NRC sets the safety bar and doesn't realize that Fermi 2 is limboing beneath it. 

Or maybe they fail to realize that safety bars are to be hurdled over rather than ducked under.

Speaking of over/under, any suggestions on just how many (within say, 10) other safety problems languish unsolved and undetected at Fermi 2? 

Thanks,

Dave Lochbaum

Arnie Gundersen, chief engineer at Fairewinds Energy Education, and an expert witness on behalf of environmental intervenors opposed to the Fermi nuclear power plant, added this comment re: Lochbaum's email and document above: 

I agree with Dave’s great analysis. Drywall coating pealing off is a decades old problem...think of leaves getting stuck in your gutter, meaning the gutters do not drain to the ground...paint chips in the drains mean the pumps can’t get access to the water even though the water is available.  “Water, water everywhere and nor any drop to pump”...A similar analogy to Samuel Taylor Coleridge: The Rime of the Ancient Mariner, "Water, water everywhere, / Nor any drop to drink."