#nuclear #Zr "Lax and flawed NRC information practices"That's Dr. Mark Kelly's polite...

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#nuclear #Zr
"Lax
and fiawed NRC information
practices". That' s Dr. Mark Kelly' s potite
description
10/CI5/ 12"
#nuclear #7r
"Lax
and flawed NRC information practices". That' s Dr.
Mark Ke[[y' s polite description
El 05:10:00 pm by Steve Schulin, Categories: nuclear planfs, lndian Point, anti-nuclear, Accidents, NRC,
Zirconium
October 5,2412
One of the documents released yesterday via ADAMS ig a 42-page statement
(including appendices) submitted by Mark Kelly of Dillsboro, Indiana. He says his
statement supports some contentions filed in opposition to license renewal of
f ndian Point units 2 and 3. I noticed that NRC's Executive Director of Operations
refers to the author as Dr. Kelly, but I don't know anything more about his
qualifications. He makes some very damning claims about NRC, and I think it's
safe to say that one of his major points involves doubt about the predicted
performance of zirconium fuel cladding during loss-of-coolant accidents. As such,
his comments apply to every conmercial nuclear plant in the nation, not
just
Indian Point.
l've included much of the first four pages of Dr. Kelly's statement here. I urge you
to download and read the rest, too, The pdf is available here.
One rnore comment before the excerpt begins: In this document, Dr. Kelly
describes how NRC essentially hides unwanted data. lt is downright ironic that
ADAMS database entry for this document shows author name of "Mary Kelly"
rather than Mark Kelly in the document title, and Kelly, M in the author name field.
... The Indian Point license renewal should not be
granted
because some of the
significant technical arguments and information pre$ented in support of relicensing
and contentions that Indian Point can continue operating safely rely directly or
indirectty upon NRC and industry information that is inaccurate or unreliable. Lax
and
flawed NRC information practices
have compromised the integrity of certain
Fphnical
information which is required for continued safe operation, maintenanpe,
opent fuel management, waste handling, accident mitigation, and design of
component and system upgrades required for continued safe operation of the
Indian Point reactors.
December ?S4
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l*tuclear #Zr "Lax and flawed NRC information practices". That's Dr. Mark Kelly's polite... Page 2 of 5
Details of flawed NRC information practices are described and specific examples
are documented in NRC records
[4],
court records
[5],
and related information
included below.
The NRC has compromised information critical to safe continuing safe operations
at lndian Point and other nuclear plants in several ways:
1) The NRC itself has generated false records that have the effect of concealing
recurring industry technical deficiencies, errors, inaccurate records, and bad QA in
the nuclear industry.
2) The NRC has stated that it would "not pursue"
di$semination of known
inaccurate and suspect technical information distributed in the nuclear industry.
3) NRC auditors have disingenuously decoupled written industry notifications to
subcontractoqs that errors in certain zirconium nuclear fuel rod cladding analyses
risked creation of significant radiological hazards from industry records
documenting that the errors in those analysis and other zirconium analyses in
support of nuclear applications repeatedly occurred and the errors were included
in reports sent to major companies in the nuclear industry.
4) The NRC has repeatedly allowed work related to nuclear fuel rod zirconium
alloy cladding integrity and high level nuclear waste containers (eg, for Yucca
Mountain waste repository project) to be performed
by companies who have
repeatedly made errors in nuclear materials analyses and who have been found to
have recurring deficiencies in their records and QA
practices directly related to
that nuclear-related work.
5) In making safety assessments which should have been based on sound
technical and scientific information, the NRC has disregarded explicit notifications
written by the client company who knew the uses of information of the type shown
to be inaccurate that defects could contribute to nuclear hazards
[6],
sworn expert
testimony describing failures and hazardous
qonsequences
that those types of
inaccuracies and resulting misunderstandings could cause during operation of
nuclear reactors
[5],
and numerous published
and reviewed studies by scientists
from the nuclear community explicitly describing degradation and safety issues
concerning the materials and data found to be inaccurate
[8-12].
(Note: some of
these studies were funded by the NRC and other U$ government agencies).
Instead, the NRC relied upon the unpublished and unreviewed limited opinions of
two selected "experts" who, like the NRC, clearly indicated that they did not know
the companies' uses of the inaccurate zirconium analysis data.
11,z|Based
on
these two limited opinions, the NRC made the broad assessment that
dissemination of known inaccurate information and suspect data on zirconium
nuclear fuel rod cladding and alloys was not safety-related and determined that
the NRC would take no action to limit spread of known bad and suspect technical
information in reports describing properties of zirconium alloys
11,21.
6) The NRC tolerates employer coercion of employees to participate in generation
of inaccurate records; in addition, the NRC generated documentation that
supports employer coercion of employees.
7) The NRC tolerates inaccurate records and information in industry that could
undermine safe operations, accident responses, waste handling, and component
design.
11,2,8-121
8) The NRC does not appear to have or require effective systems to maintain
records on component materials and other records related to operating nuclear
reactors for sufficient periods to ensure that such records are readily available if
accidents occur, when plants are decommissioned, or when waste handling
procedures are performed,
evaluated, or modified.
Itttp:llnews.nuclear.com/blog7.phplnuclear-r-lax-and-fl awed
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llnrircleat #Zr
"Lax and flawed NRC information practices". That's Dl. Mark Kelly's polite... Page 3 of 5
Reliable information is required to make good decisions. Decisions, good or bad,
guide actions. Actions have consequences. The NRC and industry's flawed
information practices could create or contribute to creation of safety hazards in the
event that the Indian Point operating license is renewed. At least five problems are
obvious.
1) Bad technical information could lead to bad decisions during continued
operations of Indian point, whose operating reactors were designed and
manufiactured over 30 years ago. Unexpected materials failures have initiated
many accidents in engineered systems decades after failed components were
placed in service.
[7]
The harsh environment of the nuclear core and waste
storage facilities degrade materials by synergistic modes involving radiation
damage, corrosion, and high temperatures during normal conditions.
[8-12]
The
histories and experiences with many of materials used in safety-critical
components only goes back a few decades, which is too short a period to develop
a good understanding of how these materials hold up under core and waste
storage conditions.
2) Bad technical and suspect information could lead to bad decisions or indecision
[7]
in event of an "excursion" from normal operating conditions or an accident at
Indian Point. Are accidents any time to ask "Can the data be trusted?"
3) Computer simulations used by industry, DOE, and other entities rely on
technical information to make projections concerning changes in materials'
performance
and degradation with time.
[12]
Such computer models are also used
in event of accidents to quickly make decisions and assess reactor component or
waste conditions. Extreme radiation, high temperatures, and other hazardous
conditions can limit the ability to make direct measurements of core and waste
container, as the ongoing Fukushima accident is demonstrating. Fast
development of unanticipated conditions that develop during an accident might
require use of computer modeling to make good
decisions quickly; often, there
simpfy isn't time to complete simulations on actual systems and components. The
urgency of an accident responses often do not allow time for evaluation of suspect
data. Accurate computer modeling requires accurate and reliable data whose
limitations are understood.
4) Safe cooling, storage, transportation, and other Indian Point waste handling
procedures require good information and understanding of materials'conditions.
t8I
5) In event of an accident at Indian Point or other facility, bad information could
lead to faulty "lessons learned". Faulty lessons learned could make accidents
wor$e. Urgent decisions concerning shutdowns of similar systems to avoid
repeating accidents could be impaired and impeded by bad and unreliable
information. Flawed information cripples failure analysis and investigations.
[7]
6) Bad information misdirects limited resources. Many arguments in favor of
renewal of the Indian Point license appear to be based on financial
considerations. NRC tolerance of bad technical industry information has
undermined financial projections because bad and suspect technical information
undermines accurate projections
of future Indian Point system performance and
component failures.
NRC Records Contain False Information and Indicate that the NRC Tolerates
Inaccurate and Suspect Information.
The four NRC documents reproduced in the Appendix below
just
before the
References demonstrate the NRC's lax information policies and generation of
false information.
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lhtclear llZt
"Lax
and flawed NRC information practices". That's Dr. Mark Kelly's polite... Page 4 of 5
In the NRC report
[1]
in Appendix Part A and 2011 letter to $enator Lugar
[2]
in
Appendix Part B, the NRC stated that the NRC practices include toleration of the
spread of bad and suspect technical information in the nuclear industry; these are
bad science and bad engineering practices.
NRC audit records documenting QA deficiencies in high level waste container
work for nuclear repositories compose Appendix Part C.
[3]
An NRC audit record
and related correspondence concerning zirconium alloy analysis compose
Appendix Part D.4 Comparison of dates in these records shows that NRC auditors
included false information in an NRC audit record. The false information conceals
recurring deficiencies in analysis of nuclear industry materials.
The NRC audit record in Appendix Part D also appears to disingenuously
disassociate procedural problems that caused errors in industry reports from
industry cautions that errors in these types of reports can create significant risks of
radiological hazards. The NRC relied upon industry information from one company
who received some of the bad materials analysis data in the NRC report
[1]and
2A11 letter to Senator Lugar
[44]
to conclude that these types of errors were
unrelated to safety
Inaccurate Information on Zirconium Nuclear Fuel Rod Cladding Properties
Was Reported to Industry.
The following are excerpts of AU hearing and deposition testimony.
[5]
The
testimony describes errors in reports intended to describe analysis results and
properties of zirconium alloys used as nuclear fuel rod cladding and other nuclear
reactor components. The property inaccurately described was the "texture" (also
called "crystallographic texture" or "preferential orientation") of zirconium alloys.
(Texture and its relationships to materials properties
and to zirconium alloys are
described below.) The inaccurate reports were generated by Lambda Research,
an industrial seMce lab. The inaccurate reports were sent to GE Nuclear,
Westinghouse, and other companies in the nuclear industry. The testimony was
given by current and a former Lambda Employee hostile to legal actions arising
from the false information, including that which included the hearing. Questions
precede the quoted testimony in order to focus attention on key admissions in the
testimony; the boldface questions are not part of the reproduced testimony, but
they
do indicate the subject of the testimony. (The court record is available
through the Office of Administrative Law Judges (AU).)
Physically impossible results on nuclear fuel rod cladding materials were
reported?
For the full pdf
of Mark Kelly's statement, click here.
Here's info about this document from NRC ADAMS database. where it was
released on October 4,2012'.
Accession Number: M L1 227 0A37 3
Estimated Page Count: 42
Document Date: Sat Sep 15 2012
Document Type: Legal-Limited Appearance Statement
Document Title: Limited Appearance Statement by Mary Kelly Opposing the
Renewal of the Licenses for the lndian Point Energy Center.
Author Name: Kelly M
Author Affiliation:
-
No Known Affiliation
Addressee Affiliation : N RC/SECY/RAS
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"Lax
and flawed NRC infonnation practices". That's Dr. Mark Kelly's polit... Page 5 of 5
Docket Number: 05000247, 05000286
Case Refu rence Numbe r: 5Q-247-LR, 50-286-LR, AS LBP 07-858-03-LR-8D01,
RAS E.1142
Keyword: DPCaut6add, Adjudicatory Doculnent
-
No SUNSI Review Needed,
dtp1,
jefl
Date Docketed: Mon Sep 17 zln
Document $tatus: EHD
Distribution List Codes: D$03
Contact Pereon: SECY RAS
File Narne: R281 488.pdf
Content $ize: 2859731.0
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