American Society of Mechanical Engineers, ASME, Boiler Code, codes, fraud, major hazards, manipulation of standards, material degradation, materials safety, NRC, nuclear energy, nuclear power, nuclear safety, reactor pressure vessel failure, reactor pressure vessels, risk management, RPV brittleness, RPV failure, standards, testing, ultrasonic testing, USNRC
From US NRC docket NRC-2011-0088: “the NRC has had a decades-long practice of approving and/or mandating the use of certain parts of editions and addenda of these ASME Codes in 10 CFR 50.55a through the rulemaking process of “incorporation by reference.”
Once again the US NRC outdoes itself for sheer stupidity. A code is a code. Standards are standards. You can’t pick and choose parts and pieces of this or any other code and say that it has anything to do with the code itself. But this is what the chronically asinine NRC wants to do: “Incorporation of American Society of Mechanical Engineers Codes and New and Revised ASME Code Cases Docket ID: NRC-2011-0088
Agency: Nuclear Regulatory Commission (NRC) “Summary
The U.S. Nuclear Regulatory Commission (NRC) is proposing to amend its regulations to incorporate by reference seven recent editions and addenda to the American Society of Mechanical Engineers (ASME) codes for nuclear power plants and a standard for quality assurance. The NRC is also proposing to incorporate by reference four ASME code cases. This action is in accordance with the NRC’s policy to periodically update the regulations to incorporate by reference new editions and addenda of the ASME codes and is intended to maintain the safety of nuclear power plants and to make NRC activities more effective and efficient.” http://www.regulations.gov/#!docketDetail;D=NRC-2011-0088 (Comment deadline Wednesday, 2 December 11.59 pm ET: http://www.regulations.gov/#!documentDetail;D=NRC-2011-0088-0003 )
Either something is up to the latest ASME (American Society of Mechanical Engineers) code standard or it is not. If the NRC does not like the ASME code then they must make their own and stop referring to ASME at all. They cannot pick and choose years of mostly outdated standards, as they please, and/or pick and choose parts of ASME, as they please, and say that it is ASME or has anything to do with ASME. It’s all or nothing. Taking pieces and parts of any code or standard could theoretically undermine part of it, or its entirety. While ASME was reportedly infiltrated, at one point, by the nuclear industry, as apparently alluded to by the NRC in this docket, one certainly cannot trust the NRC for anything other than undermining public safety. The NRC states in this docket: “The ASME Codes are voluntary consensus standards, developed by participants with broad and varied interests, in which all interested parties (including the NRC and licensees of nuclear power plants) participate.” You can look at anything we have written on the NRC to see that the NRC work more to undermine public safety than anything else. They appear to make a full-time job of it, making their “safe” Thanksgiving wish a laughable absurdity.
For that matter, you can look at anything the NRC writes and probably find that it has to do with “exemptions” or other means of undermining safety if you have a keen eye and familiarity with scientific method and maybe even if you don’t. All you have to do is know the definition of “exemption”, for instance, to know that “exemptions” are a bad thing for the nuclear industry.
The most outrageous thing yet is NRC consideration of 100 mSv yearly radiation exposure levels for the general public by the nuclear industry. This is 400 times more than the amount currently allowed by the EPA. It is so outrageously high that a decade or less of this exposure level would mean that the entire country will get cancer, according to the recent study of nuclear workers by Richardson et. al.: https://miningawareness.wordpress.com/2015/12/19/another-look-at-the-recent-low-dose-radiation-exposure-study-inworks/ https://miningawareness.wordpress.com/2015/10/21/new-study-of-us-uk-french-nuclear-workers-supports-linear-no-threshold-model-radiation-is-bad-for-you-increased-dose-is-increased-risk-hormesis-debunked-funding-from-pro-nuclear-govts-nuclea/ Given this context alone, anything said or suggested by the NRC should be looked askance and probably with alarm. The reported infiltration of ASME by nuclear lackeys suggests that everyone should await publication of the next ASME updates before making decisions, assuming that the nuclear lackeys were successfully expulsed from ASME. Based on the one comment supposedly sent in by ASME to the docket, concerned only with the design of an ASME stamp, one can start to suspect that the infiltration of ASME was an infestation of either the nuclear industry or of simple stupidity.
Why are Americans paying taxes for a bloated overpaid bureaucracy which is trying to kill Americans? The NRC is the first place to start with US budget cuts. Shut it down. Then the unemployed NRC workers can be sent to clean-up the Savannah River Nuclear site, WIPP, Hanford, Beatty, Missouri and other sites as part of welfare to work programs. Savannah River Site is a major welfare to work employer in South Carolina.
It is particularly mind-boggling that the NRC, which refuses to do ultrasonic testing on most of America’s dangerously old reactor pressure vessels suddenly expresses concern about the qualifications of ultrasonic testing personnel in this docket re ASME. Their alleged concern with determining brittleness of reactor pressure vessels is also mind-boggling given the games they are playing with public safety on this very topic. See for instance:
For nuclear reactor pressure vessel failure, from power uprates, NRC is using plus-minus 20%, which is 40% uncertainty (error-variation) and which is unacceptable by any standard. 20% uncertainly for beltline is also unacceptable. For something so dangerous they need to be at 98 to 99% certainty with a 50 to 100% contingency. Instead they say: “An extensive benchmarking program has been carried out to qualify the MPM neutron transport methodology. All of the requirements of RG 1.190 have been met. In particular, all C/M results fall within allowable limits (+/- 20% ), and it was determined that no bias need be applied to MPM fluence results. The uncertainty analysis indicates that all fluence results in the beltline region have uncertainty of less than 20%. The results of this analysis are documented in References 1 and 2. This meets the requirement of RP 1.4.1, 1.4.2, and 1.4.3.” The beltline is most at risk of embrittlement-sudden failure. They are modeling the reactor “as built”, whereas material degradation occurs over time, and the “as built” excluded the nuclear reactor power uprate. The NRC grossly abuses and misleads regarding the ASME (American Society of Mechanical Engineers) code by saying things such as “overpressurization The condition that occurs when pressure exceeds the design pressure of the component of interest by more than 10 percent, in accordance with the ASME Code“, and “Pressure in the reactor coolant and main steam systems should be maintained below 110 percent of the design values in accordance with the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code.” (NUREG-0800) which is false. The ASME standard is not 110 percent of design values. This is also an abuse of math and language. You cannot be 110 percent of the maximum! This is especially true of boiler and pressure vessels!
Furthermore, it seems that the NRC has only tested, or had tested, a few reactors for embrittlement. One must look askance at NRC alleged concerns about qualifications of ultrasonic technicians in this docket, given their apparent refusal to do needed ultrasonic testing. What do the qualifications matter if they won’t require testing to be done? Elsewhere the NRC states: “The Alternate PTS Rule is based, in part, on analysis of information from three currently operating PWRs.” (p.7) The loophole which allows this appears to be here: “III. Surveillance Program Criteria A. No material surveillance program is required for reactor vessels for which it can be conservatively demonstrated by analytical methods applied to experimental data and tests performed on comparable vessels…” http://www.nrc.gov/reading-rm/doc-collections/cfr/part050/part050-apph.html
“This action became desirable because the existing requirements, as contained in 10 CFR 50.61, “Fracture Toughness Requirements for Protection against Pressurized Thermal Shock Events” , are based on unnecessarily conservative assumptions. The Alternate PTS Rule reduces regulatory burden for those PWR licensees who expect to exceed the 10 CFR 50.61 embrittlement requirements…“(p.1) The utility funded Electric Power Research Institute (EPRI) is apparently the only “stakeholder” which they consider. (See p. 11) “Unnecessarily conservative” means that they might have forced these old reactors to be shut down, as originally planned. Read the rest; more explanation at this link (page numbers refer to this link): https://miningawareness.wordpress.com/2015/05/10/us-nuclear-reactors-brittle-fracture-failurenuclear-disaster-risk-comment-by-tues-12-may-11-59-pm-eastern-time/
Corrosion expert, Dr. Digby McDonald, recently said that all nuclear reactors, all over the world, need to be tested, all need ultrasonic survey of their reactor pressure vessels, because the degradation was worse than predicted by their models: https://miningawareness.wordpress.com/2015/03/03/nuclear-reactor-cracks-widespread-disease-scourge-warns-nobel-in-chemistry-nominee/ This is because the world population of nuclear reactors is so small (approx 435 to 443) and the repercussions of a nuclear accident so great. But, the US NRC refuses to require this testing, all while whining and complaining about ultrasonic personnel training requirements by ASME!
ASME standards are generally made by highly qualified, experienced, volunteers who take time, even doing things like missing their spouse’s birthday, to deliberate and decide the standards. They are standards. They are in the form of a code. The NRC must take ASME or leave it.
Standards are not a mix and match, take what you want and leave what you don’t, affair. Besides false advertising-misleading the public, why would such codes matter? Nuclear Reactor Pressure Vessels and High Level Nuclear waste (“Spent Fuel”) dry casks are essentially boilers, but very dangerous ones at that. When these radioactive boilers explode, deadly radioactive materials are released, and landscapes poisoned for essentially an eternity.
“ASME was founded in 1880 by Alexander Lyman Holley, Henry Rossiter Worthington, John Edison Sweet and Matthias N. Forney in response to numerous steam boiler pressure vessel failures.” https://en.wikipedia.org/wiki/ASME
“The principal causes of explosions, in fact the only causes, are deficiency of strength in the shell or other parts of the boilers, over-pressure and over-heating. Deficiency of strength in steam boilers may be due to original defects, bad workmanship, deterioration from use or mismanagement.” https://en.wikipedia.org/wiki/Boiler_explosion
Steamboat Boiler Explosion
This is not a mix and match wardrobe, or take your pick menu, as the NRC apparently wants to make it. This is a most deadly game that the NRC is playing.
On one level, the NRC may not be as stupid as they look. They just took comments to increase the radiation exposure from nuclear reactors-facilities 100 times over what they currently allow, and 400 times what the EPA allows. Clearly they are preparing for imminent nuclear disaster in the US and so standards don’t matter to them. However, what is their evac plan? There is only one planet earth connected together by winds and currents. So, while there appears to be some method in the NRC’s madness, they are clearly criminally insane or criminally stupid, all the same. Many intelligent, honest people can’t get work but these criminal psychopaths or dunces have fat-cat jobs. The NRC must be shut down for public safety’s sake, and to help balance the US budget.