NRC cites Palisades for worker radiological safety violations, record number of failures during Component Design Basis Inspections
NRC file photo of Palisades, on the Lake Michigan shore in Covert, MIAs reported by both the St. Joe-Benton Harbor Herald-Palladium and the Kalamazoo Gazette, the U.S. Nuclear Regulatory Commission (NRC) has cited Entergy Nuclear's Palisades atomic reactor (photo, left) for violations of its own workers' radiological safety protections. The violations took place in February and March 2014, during the replacement of the safety-critical Control Rod Drive Mechanisms (CRDMs), which have been plagued with problems since 1972. NRC has preliminarily designated this violation as a White Finding, "of low to moderate safety significance," which could well lead to NRC lowering Palisades' performance designation as "degraded" (NRC's findings increase in severity from Green, to White, Yellow, and Red).
Ironically enough, as during a June tour of Palisades for concerned local residents and environmental group representatives (including from Beyond Nuclear), Entergy had previously showcased the CRDM replacement as an indication of its commitment to safety.
Kay Drey, a Beyond Nuclear board member, penned a pamphlet entitled "Your Nuclear Workplace: Know Your Risks, Know Your Rights." It is posted at the NIRS website.
In summer 2010, David Lochbaum, Director of the Nuclear Safety Program at the Union of Concerned Scientists (UCS), chronicled Palisades' four decades of CRDM seal and through-wall leaks, uniquely bad in industry.
He later explained the significance of yet another through-wall leak from Palisades' CRDMs, which Entergy and NRC had allowed to go on for more than a month in summer 2012!
In addition, just today, in an email entitled "Palisades' passing grade of 50%?", Lochbaum has revealed that Palisades had more CDBI (Component Design Bases Inspection) violations than any other reactor in the country this year. Of 20 components inspected by NRC, 10 were found to be in violation at Palisades.
Lochbaum prepared a chart of documented CDBI violations nationwide in 2014. It shows that Palisades had nearly three times the rate of CDBI violations, as compared to the national average.
The chart also shows that Entergy's Pilgrim reactor (near Boston) had no such violations, and Entergy's Vermont Yankee had but one. Thus, something is clearly amiss at Palisades, even when compared to other Entergy reactors.
Regarding the CDBI violations at Palisades, Lochbaum wrote:
"Attached is a recent NRC inspection report for Palisades that was placed in their online ADAMS library yesterday. It bothers me. Part of the reason it bothers me is that it seems not to bother the NRC much, or as much as it should.
The NRC performed what it calls a Component Design Bases Inspection (see the highlighted text on page 7 of the enclosure to the NRC's transmittal letter for a description of this inspection and its purpose.)
The highlighted text at the bottom of this page indicates that the NRC's inspectors examined 20 samples. There are literally thousands of samples the inspectors could have chosen from. They selected 20 samples from among this universe.
The highlighted text at the top of page 2 of the NRC's enclosure reports that their examination of 20 samples yielded 10 violations of federal safety regulations. As bad as a 50 percent failure rate suggests, it is even worse than it seems. The NRC did not pick its 20 samples at random. The NRC did not pick its 20 samples by alphabetical order or chronological order. The NRC used risk insights to select 20 samples that would provide the best return on their resource investment as indicated by the highlighted text in the middle portion of page 7 of the enclosure. The 20 components the NRC selected to examine are among the highest risk components at the plant.
This means that these 20 components receive the greater care and attention from plant workers than the thousands of other components at the site. These 20 components receive more testing and more inspections than components like the automatic door openers in the warehouse.
Given all that care and attention by plant workers, one should expect that the NRC's inspectors would fine zero violations -- after all, finding and fixing violations is the reason workers are performing all those tests and inspections (it's not for exercise).
So, if the best effort results in half of the components having safety violations, what does that say about the quality of the rest of the components? If their quality is better, it speaks volumes about the effectiveness of the onsite testing and inspection efforts.
So, 10 safety violations from 20 components suggests that if the NRC had examined 1,000 other components, they'd have identified 500 or more additional safety violations.
The silver lining in this mess is that none of the 10 safety violations was classified by the NRC as being more serious than Green, the least serious of the NRC's four color-coded findings.
But there's no guarantee that the hundreds of other apparent safety violations undetected at Palisades will not contain more significant problems.
While the 20 components selected by the NRC have high risk, there are more than 20 high-risk components at Palisades.
What bothers me about the NRC finding 10 safety violations among only 20 high-risk components examined is that the testing and inspections conducted by plant workers should have identified these problems before the NRC found them. The clear failure of those testing and inspection efforts strongly suggests that other safety violations impairing or disabling other components at Palisades also exist and also are not being found.
The NRC must do more than ask Entergy to fix these ten safety violations. Entergy is required by federal law (specifically, 10 CFR 50 Appendix B at http://www.nrc.gov/reading-rm/doc-collections/cfr/part050/part050-appb.html) to find and fix safety problems in a timely and effective manner. The 10 safety violations documented in this NRC inspection report clearly show that Entergy is violating this federal law. Thus, the NRC must also require Entergy to fix this 11th violation. For only by fixing this violation can Entergy avoid future safety violations."
Regarding the chart of CDBI violations he prepared, Lochbaum said:
"I found a total of 16 CDBI reports in ADAMS during 2014, including the one at Palisades. The 'average' CDBI examined 18 components and identified 3.6 violations. Palisades was #1 in terms of the number and percentage of violations.
The old Hertz commercial stated they were #2 but tried harder.
I guess being #1 in these areas implies not trying very hard at all."
Beyond Nuclear hosted Lochbaum in southwest Michigan in April 2013. He spoke about his annual report on nuclear utility and NRC safety performance, or lack thereof. As revealed by Lochbaum's report, Palisades had one of the single worst safety performance records of any reactor in the country, in terms of the number of "near misses."
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On Feb. 23, 2015, NRC officially concluded that the Feb.-March, 2014 over-exposure of 192 workers at Palisades to an average dose of 2.8 Rem constituted a White Finding. See the NRC's Final Significance Determination, here.