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The US NRC has another laundry list of things to comment upon: http://www.regulations.gov/#!documentDetail;D=NRC-2015-0088-0001 ID: NRC-2015-0088-0001, Deadline 14 May

They appear written by a 1960s cartoon computer – the one that the characters ultimately hit from frustration until the springs pop out. They are the epitome of bureaucratic stereotype. It seems impossible that they were written by a human. If something changes a rule which enhances safety, it is treated the same as something which weakens safety. In both instances they are called “no significant hazards”. Written in a way that no one can fathom, it breaks the clear writing law.
Eager orientalists examine the Rosetta Stone in 19th Century London. (Public domain.)
Examining the Rosetta Stone in 19th Century London

They even refer to the wrong document in a least one instance. The only way to understand is to do research on the topic, read between the lines, and assume that they are up to no good unless proven otherwise. The vast majority are almost certainly dangerous sneak throughs, though we have found one that may be a safety improvement.

Apparent Safety Downgrades for Arkansas Nuclear One are on this laundry list of documents to comment, even as the NRC claims to be doing extra safety monitoring of it! https://miningawareness.wordpress.com/2015/05/07/multiplerepetitive-degraded-arkansas-nuclear-one-public-hearing-may-12-comment-deadline-may-14/

This move to hot shutdown has happened or is happening throughout the US, it seems.
Arkansas One Nuclear google and www.psr. org http://www.psr.org/resources/evacuation-zone-nuclear-reactors.html
The 10 mile evac plan for Arkansas Nuclear: http://www.fema.gov/media-library-data/20130726-1919-25045-1433/communicating_during_and_after__npp_incident___june_2013__secure_.pdf

Comment and information here (search for Arkansas in page): http://www.regulations.gov/#!documentDetail;D=NRC-2015-0088-0001 ID: NRC-2015-0088-0001

Clues from a document:
TSTF-422 is one of the industry’s initiatives Yes, there you go. It’s a nuclear industry initiative. Westinghouse seems to have been a major player on this dating back to when Westinghouse was owned by the UK gov (BNFL) and merged with ABB Nuclear; more recently Toshiba owned Westinghouse appears to be pushing it: “developed under the Risk Management Technical Specifications (RMTS) program. These initiatives are intended to maintain or improve safety through the incorporation of risk assessment and management techniques in TS, while reducing unnecessary burdenThe nuclear industry considers safety an unnecessary burden.and making TS requirements consistent with the Commission’s other risk-informed regulatory requirements, in particular the maintenance rule.“Risk-informed” means that they are willing to gamble with health and safety because under the Price Anderson Act there are few repercussions to them in the event of an accident.

The regulation at Title 10 of the Code of Federal Regulations (10 CFR) Section 50.36, “Technical Specifications,” states: “When a limiting condition for operation [LCO] of a nuclear reactor is not met, the licensee shall shut down the reactor or follow the remedial action permitted by the technical specification until the condition can be met.” The STS and most plant TS provide a completion time (CT) for the plant to meet the LCO. If the LCO or the remedial action cannot be met, then the reactor is required to be shut down. When the STS and individual plant TSs were written, the shutdown condition or end state specified was usually cold shutdownhttp://pbadupws.nrc.gov/docs/ML1032/ML103270197.pdf
They wish to change that.

The Breakthrough clue was LCO 3.0.4.a, which appears throughout the amendments as not applicable, something to be no longer considered.

This describes Mode 4 and 5. Hot Shutdown is 200-300 F and Cold Shutdown is 200 degrees F or less. Perhaps most important for safety is that the pressure is also reduced going from hot to cold shutdown. Additionally at the cooler shutdown it is less likely to undergo thermal shock. Toward the bottom of the post is a summary of Idaho National Lab’s research on Cold and Hot shutdowns.
ML103270197 p. 2 Hot-Cold Shutdown defined
ML103270197, p. 5 Water LOCA
ML103270197, p. 12 Pressure Hot Shutdown AR
Much more here: http://pbadupws.nrc.gov/docs/ML1032/ML103270197.pdf ML103270197
MODEL SAFETY EVALUATION FOR PLANT-SPECIFIC ADOPTION OF TECHNICALSPECIFICATIONS TASK FORCE TRAVELER TSTF-422, REVISION 2, “CHANGE IN TECHNICAL SPECIFICATIONS END STATES, (CE NPSD-1186),” FOR COMBUSTION ENGINEERING PRESSURIZED WATER REACTOR PLANTS USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS“ML103270197 (Emphasis our own.)
ML15068A319-1 p. 12 Arkansas unit 2 amendments Reactor Coolant System
ARKANSAS NUCLEAR ONE, UNIT NO. 2 – ISSUANCE OF AMENDMENT RE: REVISE TECHNICAL SPECIFICATIONS END STATES (TAC NO. MF1199) Much more here: http://pbadupws.nrc.gov/docs/ML1506/ML15068A319.pdf
(Emphasis added)

Of course, the NRC just approved the storage of broken fuel in flimsy Holtec casks. Fuel in broken casks can’t be moved, so Arkansas is in big trouble anyway. In the middle of the country, it is a major hazard to America. From Chernobyl we know that radiation travels far and wide.

Comment deadline 14 May: http://www.regulations.gov/#!documentDetail;D=NRC-2015-0088-0001

Entergy Operations, Inc., Docket No. 50-368, Arkansas Nuclear One, Unit No. 2 (ANO-2), Pope County, Arkansas Date of application for amendment: March 26, 2013, as supplemented by letters dated December 12, 2013, and May 12, August 19, October 22, and December 5, 2014.

Brief description of amendment: The amendment revised the ANO-2 Technical Specification (TS) requirements for end states associated with the implementation of the NRC-approved Topical Report NPSD-1186, Revision 0, “Technical Justification for the Risk Informed Modification to Selected Required Action End States for CEOG [Combustion Engineering Owners Group] Member PWRs [Pressurized-Water Reactors],” as well as Required Actions revised by a specific Note in TS Task Force (TSTF) change traveler TSTF-422, Revision 2, “Change in Technical Specifications End States (CE NPSD-1186).” The Notice of Availability for TSTF-422, Revision 2, was announced in the Federal Register on April 7, 2011 (76 FR 19510).
Date of issuance: March 31, 2015.

Effective date: As of the date of issuance and shall be implemented within 90 days from the date of issuance.
Amendment No.: 301. A publicly-available version is in ADAMS under Accession No. ML15068A319; documents related to this amendment are listed in the Safety Evaluation enclosed with the amendment.

Renewed Facility Operating License No. NPF-6: Amendment revised the Technical Specifications/license.
Date of initial notice in Federal Register: July 23, 2013 (78 FR 44172). The supplemental letters dated December 12, 2013, and May 12, August 19, October 22, and December 5, 2014, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the staff’s original proposed no significant hazards consideration determination as published in the Federal Register.

The Commission’s related evaluation of the amendment is contained in a Safety Evaluation dated March 31, 2015.
http://www.regulations.gov/#!documentDetail;D=NRC-2015-0088-0001

According to an Idaho National Lab article: “Based on this analysis of PWRs, the risk to fuel damage (per hour) during shutdown operations is comparable to at-power operations.” (See below)

Development of Standardized Probabilistic Risk Assessment Models for Shutdown Operations Integrated in SPAR Level 1 Model S. Khericha, Ph. D. a* , J. Mitman b
a Idaho National Laboratory, Idaho Falls, ID, USA b U.S. Nuclear Regulatory Commission, Washington DC, USA

Abstract: Nuclear plant operating experience and several studies show that the risk from shutdown operation during Modes 4, 5, and 6 at pressurized water reactors and Modes 4 and 5 at boiling water reactors can be significant. This paper describes using the U.S. Nuclear Regulatory Commission’s full-power Standardized Plant Analysis Risk (SPAR) model as the starting point for development of risk evaluation models for commercial nuclear power plants. The shutdown models are integrated with their respective internal event at-power SPAR model. This is accomplished by combining the modified system fault trees from the SPAR full-power model with shutdown event tree logic. Preliminary human reliability analysis results indicate that risk is dominated by the operator’s ability to correctly diagnose events and initiate systems.

Keywords: probabilistic risk assessment, shutdown, operating modes, outage

1. INTRODUCTION

The Idaho National Laboratory (INL) is in the process of developing shutdown probabilistic risk assessment (PRA) models for the U.S. Nuclear Regulatory Commission (NRC) to estimate the risk from shutdown operations. The shutdown models are built in the existing U.S. NRC full-power Standardized Plant Analysis Risk (SPAR) Level 1 model. References [1] and [2] provided the starting point for developing the event tree structure, plant operating state (POS) information, and other items specific to shutdown operations. Reference [1] delineates six technical specification operating modes for a pressurized water reactor (PWR) and breaks them down into 15 POSs. Reference [2], for a boiling water reactor (BWR) addresses the five technical specification operating modes with nine POSs. Modes 4, 5, and 6 for PWRs and Modes 4 and 5 for BWRs primarily require the residual heat removal (RHR) system. Core damage frequency was analyzed for only the one POS that significantly dominated the risk for each plant type. In the case of PWRs, this is the mid-loop operating state (POS 5); for BWRs, it is reactor coolant system (RCS) level normal until the vessel head is off (POS 4) (References 1 and 2).

In 2000, INL analysts developed an approach to estimate core damage frequency for shutdown operations. As stated in References [3] and [4], most of the risk from shutdown operations arises from Mode 4 (hot shutdown), Mode 5 (cold shutdown), and Mode 6 (refueling) for PWRs and Mode 4 (cold shutdown) and Mode 5 (refueling) for BWRs. The three PWR modes are further delineated into a total of 12 POSs based on the status of the primary system. It is implicitly assumed here that when a PWR transitions from Mode 3 to Mode 4, heat removal from the primary system switches from the steam generators to the RHR system. The two BWR modes are further delineated into a total of seven POSs based on the status of the primary system. These POSs were mapped into four time windows to characterize the shutdown operations. The time windows define average decay heat generation rate. A specific POS can be split into more than one time window. Although much of the data from References [1] and [2] were used, they were reformatted to accommodate an analysis based on technical specification defined operating modes.

In 2006, INL analysts further modified the analyses to integrate shutdown risk with internal and external events analyses. This changed the focus of the model from calculating only the overall risk integrated over a complete outage to a model that is also useful as an event or condition evaluation tool. Therefore, the emphasis on mapping of time window versus POS has been eliminated. In effect, the model now calculates risk for a single time window for a given POS. An analyst can adjust the model for situations in which an extended timeline can have a significant effect on the operator action and consequently the level of risk.

Based on similar mitigating system applicability, the evolution of a plant outage has been delineated into nine POSs for PWRs and six POSs for BWRs. Only those plant configurations that rely primarily on the RHR system for removal of primary system decay and residual heat are included in this analysis. These mode-based plant operating states are described in the next section. This shutdown model is constructed using the system fault tree models, common cause failure modeling, and most of the basic event definition and quantification from the full-power SPAR model.
[…]
3. CHARACTERIZATION OF PRESSURIZED WATER REACTOR SHUTDOWN OPERATIONS

The set of POSs selected for inclusion in the shutdown SPAR models were defined in an analysis of the transitions and configurations associated with plant shutdown, outage, and startup operations. Naming conventions similar to those used in References [3] and [4] have been followed, and can be used to associate event trees, fault trees, and basic events with a particular initiating event and plant state. The POS names are based on a six-character identifier that defines five POS characteristics: • Plant mode M4 Mode 4 M5 Mode 5 M6 Mode 6 • Time frame (in relation to refueling mode) E Early (before refueling) L Late (after refueling) X Not applicable (refueling mode) • Pressure (not applicable to PWR) L Low or atmospheric H Hydro test • RCS inventory status PWR: BWR: R Reduced RCS inventory N Normal RCS inventory F Full RCS inventory S Steam-line RCS inventory C Cavity flooded U Cavity flooded • RCS pressure boundary status (not applicable to BWR) V Vent open in the RCS pressure boundary I Intact RCS pressure boundary • RCS loop status (not applicable to BWR) B Blocked RCS loops (i.e., all steam generators are isolated from the rest of the RCS) O Open RCS loops (i.e., RCS flow through the steam generators is possible).
[…]
9. CONCLUSION

Because of the very limited number of automatic equipment actions that are typically functional during shutdown, operator actions are more dominant during shutdown than during at-power conditions. The risk is dominated by the operator’s understanding of the event and the ability to respond appropriately. In the example PWR, more than 98% of the core damage frequency was dominated by operator actions. Several core damage cutsets include three or more operator actions. Therefore, understanding and modeling dependency of operator actions is a very important aspect of the total risk. Based on this analysis of PWRs, the risk to fuel damage (per hour) during shutdown operations is comparable to at-power operations. http://www5vip.inl.gov/technicalpublications/Documents/3901029.pdf

These Arkansas reactors probably led to the early death of a rare politician who was also a good man – Win Rockefeller of Arkansas. WinRock farms is well within the 50 mile evacuation area for growing food and downriver from the reactors. He died in his 50s of myeloproliferative disease – a leukemia precursor, which can be caused by radiation exposure. What a sad story. Good, rich, generous with an open hand – no strings attached. Much needed and rare and dead in his 50s. He might have been president. WinRock International promotes renewable energy around the world. http://en.wikipedia.org/wiki/Winthrop_Paul_Rockefeller http://umm.edu/health/medical/altmed/condition/myeloproliferative-disorders

Where are the Clintons on this? Like Bono doesn’t give a rats arse about Sellafield and the Irish Sea anymore, they clearly don’t give a rats ass about Arkansas. Bill used to. Hillary probably never did. She is a Chicago girl. Bill and Bono prefer to help the African peoples who are very capable of taking care of themselves. It’s Arkansas and the Irish Sea which need their help. There’s actually 2 reactors at Arkansas Nuclear One. Arkansas One has so many problems, such as a fire and a dead worker, and stored broken fuel in a Holtec cask.

LCO 3.0.4: “LCO 3.0.4 establishes limitations on changes in MODES or other specified conditions in the Applicability when an LCO is not met. It allows placing the unit in a MODE or other specified condition stated in that Applicability (e.g., the Applicability desired to be entered) when unit conditions are such that the requirements of the LCO would not be met, in accordance with LCO 3.0.4.a, LCO 3.0.4.b, or LCO 3.0.4.c.

LCO 3.0.4.a allows entry into a MODE or other specified condition in the Applicability with the LCO not met when the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time. Compliance with Required Actions that permit continued operation of the unit for an unlimited period of time in a MODE or other specified condition provides an acceptable level of safety for continued operation. This is without regard to the status of the unit before or after the MODE change. Therefore, in such cases, entry into a MODE or other specified condition in the Applicability may be made in accordance with the provisions of the Required Actions.
http://pbadupws.nrc.gov/docs/ML1210/ML12104A193.pdf

If that didn’t make any sense to you, don’t waste too much time looking at it. It was the repetition in context that allowed the breakthrough. That definition is like trying to find the meaning of a word in a foreign language, of a different language family, in a foreign language dictionary.

If you don’t feel that you understand enough to complain to the NRC about content, please complain about the unreadable nature of their documents. The NRC gambles with your life, while stealing your tax dollars to pay their fat salaries. They can at least make the information readable.

[Emphasis added throughout.]