Responsible Use of the ISA....for dummies

The difference between the general public repeatedly being shown acceptable safety conditions by an alarmist press wrongly deeming them possible emergencies, and a truly degraded or dangerous nuclear plant , ...has not been made sufficiently clear.

Even an absolute collapse of local political confidence in NRC and its day-to-day oversight cannot be solved by re-inspecting all 104 nuclear plants whenever a local political figure gains traction for the idea in his/her constituency. Such a development can only result in the squandering of resources, funding, and effort into situations not warranting such activity. Taken to its extrapolated worst case, this strategy would flood all 104 nuclear plants with hordes of intrusive inspectors, impeding plant operations, and possibly inducing the very events they came to inspect against.

One of the first principles espoused in the international IAEA document 75-INSAG-3, "Basic Safety Principles for Nuclear Plants", in its preamble by nobel laureate Mohammed El Baradei, is that effort must be targeted to need. "It is important to avoid concentrating resources on efforts that have only marginal effects"..

With local governmental figures voicing ephemeral concerns brought to their attention from activist, intervenor, and opposer groups, outside of any indication that acceptable safety has truly been compromised, we see a clear need for a high level separation of fact and claim, perhaps by a national or international committee, establishing guidelines, and trip-points for the beneficial use of independent safety assessments, and likewise setting precise indicators barring the frivolous use of ISA as a political panacea.

The basic safety case for each of the 104 American nuclear plants has been set out in their Preliminary Safety Analysis Report and their Final Safety Analysis Report. Deterministic comparison of each plant's adherence to its written safety case is provided in real-time by the presence of resident NRC inspectors, and the NRC Reactor Oversight Program.

Probabilistic analysis of the major US plant types can be done by qualified researchers at any time, setting out the risks versus the probabilities in general, allowing guidelines to stand as required reading for those who would inspect, and re-inspect, frivolously, without knowing anything at all about the limits of mere inspection.

(Inspection as a tactic cannot predict an unforseen event. The very evening an ISA is completed at plant "X", a meteor could strike the containment dome, and breach the reactor core--- the inspection would have been a total waste of time).

Politicians ignorant of Probabilistic Risk Analyses seek an absolute "How Safe Is It?" answer , one that eternal inspection, by its very nature, cannot supply. PRA can provide that overview. Therefore politicians should direct the Congressional Research Service to commission a national PRA report on the 104 reactors, as their own internal legislative guide on how to avoid useless calls for repeat ISA's. In point of fact, politicians have been slyly misguided by intervenor and opposer public relations operatives posing as "technical experts", and given the Maine Yankee ISA & shutdown as the one and only way to find out if your local nuke is dangerous. Actually, the MY ISA found the plant was acceptable for further operation. It was a bereft conglomerate corporate culture that had no further interest in its nuclear asset, and bailed out. So even in the case of Maine Yankee, the public was never told how safe the plant was, or was not.

In the face of this impossibility to get blood from a stone, vis-a-vis the ISA tactic, politicians must be educated where to look for this information. I would challenge Senator Clinton and Congressman Hall to write up legislation empowering NRC or CRS to do a "PRA Constitutional Report" on each of the American reactors, with appropriate funding and a clear legislative charter., and to report the results in a high level national safety assessment.

After this report had scientifically charted the relative safety of all 104, then , and only then, would ISA become a useful tool, targeted at whatever specific need had been scientifically unearthed in the PRA Constitutional. This also has the benefit of closely following the IAEA methodology set out in 75-INSAG-3, the high-level agenda-free international document most trustworthy as an authority in these matters.

Without such a framework, any call for an ISA, without clearly demonstrated need, can rightly be called frivolous misuse of legislative priviledge. Within such a framework, established need can form the basis of any future calls fo an ISA.

Reference Documents may be found at:

http://www-pub.iaea.org/MTCD/publications/PDF/P082_scr.pdf , links to the current international standard for safety at nuclear plants. "75-INSAG-3"

http://www-pub.iaea.org/MTCD/publications/PDF/Pub991e_web.pdf, is the IAEA publication setting the international standard for judging safety in nuclear plants built to earlier standards.
The document is named "INSAG-8"

Use your ISA Responsibly, or not at all

The difference between the general public repeatedly being shown acceptable safety conditions by an alarmist press wrongly deeming them possible emergencies, and a truly degraded or dangerous nuclear plant , ...has not been made sufficiently clear.

Even an absolute collapse of local political confidence in NRC and its day-to-day oversight cannot be solved by re-inspecting all 104 nuclear plants whenever a local political figure gains traction for the idea in his/her constituency. Such a development can only result in the squandering of resources, funding, and effort into situations not warranting such activity. Taken to its extrapolated worst case, this strategy would flood all 104 nuclear plants with hordes of intrusive inspectors, impeding plant operations, and possibly inducing the very events they came to inspect against.

One of the first principles espoused in the international IAEA document 75-INSAG-3, "Basic Safety Principles for Nuclear Plants", in its preamble by nobel laureate Mohammed El Baradei, is that effort must be targeted to need. "It is important to avoid concentrating resources on efforts that have only marginal effects"..

With local governmental figures voicing ephemeral concerns brought to their attention from activist, intervenor, and opposer groups, outside of any indication that acceptable safety has truly been compromised, we see a clear need for a high level separation of fact and claim, perhaps by a national or international committee, establishing guidelines, and trip-points for the beneficial use of independent safety assessments, and likewise setting precise indicators barring the frivolous use of ISA as a political panacea.

The basic safety case for each of the 104 American nuclear plants has been set out in their Preliminary Safety Analysis Report and their Final Safety Analysis Report. Deterministic comparison of each plant's adherence to its written safety case is provided in real-time by the presence of resident NRC inspectors, and the NRC Reactor Oversight Program.

Probabilistic analysis of the major US plant types can be done by qualified researchers at any time, setting out the risks versus the probabilities in general, allowing guidelines to stand as required reading for those who would inspect, and re-inspect, frivolously, without knowing anything at all about the limits of mere inspection.

(Inspection as a tactic cannot predict an unforseen event. The very evening an ISA is completed at plant "X", a meteor could strike the containment dome, and breach the reactor core--- the inspection would have been a total waste of time).

Politicians ignorant of Probabilistic Risk Analyses seek an absolute "How Safe Is It?" answer , one that eternal inspection, by its very nature, cannot supply. PRA can provide that overview. Therefore politicians should direct the Congressional Research Service to commission a national PRA report on the 104 reactors, as their own internal legislative guide on how to avoid useless calls for repeat ISA's. In point of fact, politicians have been slyly misguided by intervenor and opposer public relations operatives posing as "technical experts", and given the Maine Yankee ISA & shutdown as the one and only way to find out if your local nuke is dangerous. Actually, the MY ISA found the plant was acceptable for further operation. It was a bereft conglomerate corporate culture that had no further interest in its nuclear asset, and bailed out. So even in the case of Maine Yankee, the public was never told how safe the plant was, or was not.

In the face of this impossibility to get blood from a stone, vis-a-vis the ISA tactic, politicians must be educated where to look for this information. I would challenge Senator Clinton and Congressman Hall to write up legislation empowering NRC or CRS to do a "PRA Constitutional Report" on each of the American reactors, with appropriate funding and a clear legislative charter., and to report the results in a high level national safety assessment.

After this report had scientifically charted the relative safety of all 104, then , and only then, would ISA become a useful tool, targeted at whatever specific need had been scientifically unearthed in the PRA Constitutional. This also has the benefit of closely following the IAEA methodology set out in 75-INSAG-3, the high-level agenda-free international document most trustworthy as an authority in these matters.

Without such a framework, any call for an ISA, without clearly demonstrated need, can rightly be called frivolous misuse of legislative priviledge. Within such a framework, established need can form the basis of any future calls fo an ISA.

Reference Documents may be found at:

http://www-pub.iaea.org/MTCD/publications/PDF/P082_scr.pdf , links to the current international standard for safety at nuclear plants. "75-INSAG-3"

http://www-pub.iaea.org/MTCD/publications/PDF/Pub991e_web.pdf, is the IAEA publication setting the international standard for judging safety in nuclear plants built to earlier standards.
The document is named "INSAG-8"

ALICE ENTERS WONDERLAND

Jim Knubel's article in TJN recaps some points made over the weeks here about the press-burst spewed by local Democratic party notables last month, talking about an "Independent Safety Assessment" at Indian Point. One spot where Knubel and I disagree, is when he asserts that all the Demo-clique members want to simply close Indian Point. If and when positive press can be gained by spouting a "Shut it down" line, I'm sure any one of these professional issue hoggers would say exactly what would help them the most, in the public eye.

I find the fact that they are NOT saying "Shut it down" very telling.

The public wants the benefits of having Indian Point on line, and our savvy politicoes are aware of this want, based on an undenied general need. However, having been elected partly via the efforts of paid green and NIMBY groups, the Dems are hoist on the horns of a service dilemma.

If they appear to serve the public, they lose their partisan support.

If they serve the activists, they lose, bigtime, for the region and the public at large.

Their Solution?
Call for Alice in Wonderland to step in.

By banding together to demand an unneeded and obsolete ISA, they can appear reasonable to the public, while at the same time appearing to their contributing activist foundations to at least be "punishing the demon".
It's PR magic. They get to do nothing, and look green doing it.

What is truly needed, is a re-assessment of the Luddite myth-mongering cartel that has been employing long term paid PR hacks to cook up astroturf pseudo-grassroots "concern", spewing distortions, and attempting to set society against itself, to benefit their purely private no-nukes agenda.

Democratic researchers might start with the names Helene Heilbrunn Lerner, Alice Slater, G.R.A.C.E., Tamarind Foundation, and the Rockefeller Foundation, along with Amsterdam Based N.I.R.S./WISE. A veritable crap-storm of fear-drenched nonsense has been put on the street for at least a decade by these oligarchs-in-camouflage, pawning their social-engineering experiment as "grassroots" concern. Google it for yourself. They total maybe 50 people. (but wield a billion PR dollars). That's who is "concerned", not anybody else. Don't let paid PR footsoldiers claim to represent the public. They do not.

Ironically, all our local Democratic officeholders
inadvertently admit they know this to be true,
by calling for an ISA.
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GRANDSTANDING FOR ECO-PAPPARAZZI ?

I was amazed to find the entire 2006 evaluation of Entergy's Indian Point Energy Center publicly available at the following NRC website urls:

http://www.nrc.gov/NRR/OVERSIGHT/ASSESS/IP2/ip2_chart.html

http://www.nrc.gov/NRR/OVERSIGHT/ASSESS/IP3/ip3_chart.html

Linking on to the public site, I was able to see that both units had all "Green" ratings for 2006, where green is performance within acceptable safety parameters, and a further list of all the coaching points NRC had brought to advise the units how to do better.

These are known as "findings" A finding is an area that NRC wants to see improvement on. A green finding has no safety impact, and is NOT a violation, simply a coaching point, on how to improve.

By reading through the green findings for IP2 & IP3, I was able to gain a feel for how the plants were coping. As in the GAO-2006-1029 report quoted earlier on this blog, it seems to the interested reader, to be fairly clear that things are going well at Indian Point.

So two separate agencies of the United States Federal Government agree on this. The NRC, a quasi-judicial agency of the executive branch, and the General Accountability Office, a pure investigative agency of the Democrat-dominated Legislative branch. The GAO report covers the years from 2001 through 2005, and the NRC report covers 2006.

How deflating it must be, for agendist local politicians to read that these two prestigious expert agencies both agree that Indian Point is completely safe, and running well, in dovetailing reports done at separate times by separate agencies, agencies with widely differing missions to serve.

It ought to be a clarifying experience, allowing politicians and the public to determine just who is bullshitting whom, vis-a-vis Indian Point. What part of "Safe" do they not understand? What part of "Well Run" do they not understand?

And as far as "Fine-'em" Feiner, who declared he wants NRC to take money from Entergy, it also answers his big attention grabbing media stunt-question of last week. When Feiner ingenuously asks "Why is Indian Point not being fined?" the NRC answer is: "Indian Point has no findings greater than Green".--- in plain words---There's nothing to fine. Read the two reports, and it will be explained to you, and to Feiner, and John Hall, Hillary, and Chuck-the-cluck Schumer, too.

NRC does not fine plants that are running safely. NRC does not interrupt its valuable & deeply revealing Reactor Oversight Inspections, to do uncalled-for, attention-grabbing Independent Safety Assessments.

So where does that leave the Gang-of-Six? It leaves them waving their little red books as they march around their little Tien Anmen Square mockup in the local press in Mao-like lockstep,
shouting their antinuke red guard slogans, to display their proper political orientation to all their papparazzi in media, who have always liked a communal demonstration, with slogans, even better than reality.

DOESN'T ANYBODY READ THIS STUFF?

HAVEN'T YOU READ YOUR OWN GAO REPORT?


In response to Several Democrats' call for an Independent Safety Assessment at Indian Point, I decided to see what resources were out there, if I were a congressperson, and just wanted to know how well NRC was managing Indian Point, without passing a special law, or holding a lot of wasteful press conferences.

And Whaddya know! I didn't have to believe NRC. I didn't have to ask Entergy. And I didn't have to pass a new law, either! The GAO, Congress' own investigative arm, had already published a report in September, 2006, describing just how well NRC was doing, managing the oversight of Indian Point.

I couldn't believe it! Had the anti-nuclear staffers of these Democrats hidden the GAO report from them? Probably, is my own conclusion.

Anyway, the report contains tables, showing Indian Point's safety rating improving continuously, since 2001. (2001 was the year that Entergy bought the place, by the way). The same charts show Indian Point firmly "In the Green". I guess that ought to reassure Hillary, and Mr Hall, Schumer & Hinchey.

All they have to do is read this post, or link to:
http://www.gao.gov/new.items/d061029.pdf
They don't have to even bother Congress with a useless new brouhaha, attracting a lot of attention, and wasting $20 million doing it! Of course, you don't get any media coverage, reading a report!



GAO-06-1029
September 2006


NUCLEAR
REGULATORY
COMMISSION
Oversight of Nuclear
Power Plant Safety
Much Improved

(these are exerpts, the whole report is much longer).

NRC provides an overall assessment of each plant’s performance through assessment letters issued to plants at the end of each 6-month period describing their specific performance and the level of oversight that will result. In addition, NRC has mechanisms to make available its oversight results, such as an Internet Web site devoted to the ROP that provides detailed summaries of each plant’s performance.

In the area of performance indicators, there were 156 instances out of more than 30,000 reports, or less than 1 percent, in which data reported for individual indicators were outside of NRC’s acceptable performance category. NRC assesses overall plant performance and communicates the results to licensees and the public on a semiannual basis.

Since 2001, the ROP has resulted in more than 4,000 inspection findings concerning nuclear power plant licensees’ failure to fully comply with NRC regulations and industry standards for safe plant operation, and NRC has subjected more than 75 percent (79) of the 103 operating plants to increased oversight for varying periods.

In addition, the nuclear power industry formed an organization, the Institute of Nuclear Power Operations (INPO), whose mission is to “promote the highest levels of safety and reliability, to promote excellence, in the operation of nuclear electric generating plants.” INPO provides a system of personnel training and qualification for all key positions at nuclear power plants, and workers undergo both periodic training and assessment. INPO also conducts periodic evaluations of operating plants, focusing on plant safety and reliability, in the areas of operations, maintenance, engineering, radiological protection, chemistry, and training. Licensees make the results of these evaluations available to NRC for review, and NRC staff use the evaluations as a means to determine whether its oversight process has missed any performance issues.


NRC increased its inspection resources by 9 percent in 2004, and then by another 5 percent in 2005, and was able to fully implement its baseline inspection program at all plants for both years. NRC reports show that resources expended in 2005 were almost 20 percent higher than those expended in 2002.With its current resource levels, NRC program officials believe they will be able to continue to implement all program requirements.


Physical plant inspections are the main tool NRC uses to oversee plant safety performance. NRC defined specific inspection areas by developing a list of those elements most critical to meeting the overall agency mission of ensuring nuclear power plant safety. These safety elements—or key plant inspection areas—are known as cornerstones.


During fiscal year 2005, NRC reported that inspectors spent 411,490 hours on plant inspections, which consist of baseline, supplemental, and special inspections. About 73 percent of this time was devoted to baseline inspections, which are conducted on an almost continuous basis. Baseline inspections are conducted by the NRC inspectors located at each site and specialists who travel to each site from NRC’s regional offices. These inspections are designed to detect declining safety performance in each of the cornerstones, and to review licensee effectiveness at identifying and resolving its safety problems. There are more than 30 baseline inspection procedures conducted at intervals that range from quarterly to triennially. Each of the baseline procedures specify a range of sample activities to inspect. Inspectors then select the type and number of activities to review on the basis of factors such as the sample activities available; their risk significance; the amount of time since a particular system or component was last inspected; and the inspector’s judgment, which is based on information such as reviews of the licensee’s corrective action program, allegations, or plant employee interviews. Risk is factored into the baseline inspection procedures in the following four ways: (1) areas of inspection are included in the set of baseline procedures, in part, on the basis of their risk importance; (2) risk information is used to help determine the frequency and scope of inspections; (3) the selection of activities to inspect within each procedure is informed with plant-specific risk information; and (4) the inspectors are trained in the use of risk information in planning their inspections. In addition to the more than 30 baseline inspection procedures, inspectors spend an average of 750 to 1,100 hours per year, conducting plant status reviews. These reviews are to ensure that inspectors are aware of plant conditions on a routine basis and include such activities as reviewing control room activities and status, attending licensee meetings, and conducting walk-downs of various plant areas.


Whether NRC takes enforcement actions in response to plant performance problems depends on whether there is a violation of a specific regulatory requirement.


When NRC issues greater-than-green inspection findings at a plant, it conducts supplemental inspections. One plant was subject to NRC’s highest oversight level in 2001 & 2002 because of a red finding for the failure of a steam generator tube. NRC conducted its most intensive supplemental inspection 2 months after the red finding was determined The licensee prepared a plan to address its deficiencies, and determined that a multiyear effort was necessary to develop and implement all corrective actions. Once the corrective actions were in place, NRC inspectors conducted follow-up inspections to examine the adequacy of the licensee’s efforts. Supplemental inspections, performed by regional staff, expand the scope beyond baseline inspection procedures and focus on diagnosing the cause of the performance
deficiency. There are three levels of supplemental inspections that are increasingly expansive in the breadth and depth of their analysis. The lowest level of supplemental inspection assesses the licensee’s corrective actions to ensure they were sufficient in both correcting the problem and identifying and addressing the root and contributing causes to prevent recurrence. The second level of supplemental inspection has an increased scope that includes independently assessing the extent of the condition for both the specific and any broader performance problems. The highest level of supplemental inspection is even more comprehensive and includes determining whether the plant can continue to operate and whether additional regulatory actions are necessary. The highest level of supplemental inspection is usually conducted by a multidisciplinary team of NRC inspectors and may take place over several months. Also, as a part of this supplemental inspection, NRC inspectors assess the adequacy of the licensee’s overall programs for identifying, evaluating, and correcting its performance issues, among other things.



In addition to its various inspections, NRC also collects plant performance information through its performance indicator program, which it maintains in cooperation with the nuclear power industry. On a quarterly basis, each plant submits data for 15 separate performance indicators—quantitative measures of plant performance related to safety in the different aspects of plant operations. Working with the nuclear power industry, NRC set thresholds for acceptable performance and assigned colors to each of the indicators to reflect increasing risk. In contrast to inspection findings, a green indicator does not indicate a performance deficiency but instead reflects performance
within the acceptable range, while white, yellow, and red represent decreasing levels of plant performance. NRC inspectors review and verify the data submitted for each performance indicator annually through their baseline inspections



On the basis of the results of its oversight process, NRC provides plant licensees and the public with an overall assessment of each plant’s performance. At the end of each 6-month period, NRC issues an assessment letter to each plant to describe its placement on the action matrix, what actions NRC is expecting the plant licensee to take as a result of the performance issues identified, any specific enforcement actions NRC has taken, and any documented substantive cross-cutting issues. If a substantive cross-cutting issue is identified, the letter will describe what actions NRC intends to take to monitor the issue and how the licensee is expected to respond to NRC with the corrective actions it intends to take. NRC also holds an annual public meeting at or near each site to review its performance and address questions from members of the public and other interested stakeholders.

In addition, NRC reviews the conclusions of independent plant assessments, such as those conducted by INPO. The purpose of this review is to selfassess the NRC inspection and assessment process to ensure that NRC is identifying similar performance issues.

NRC communicates the results of much of its oversight process to members of the public through an Internet Web site devoted to the ROP. This Web site makes available plants’ inspection reports and assessment letters, and other general materials related to NRC’s oversight process. NRC also provides a quarterly summary of every plant’s performance, consisting of its inspection findings, the color of each performance indicator, and its placement on the action matrix. NRC also provides a
short description of each inspection finding issued during the quarter.


In addition to its plant-level assessments, NRC assesses the results of its oversight process on an industry-level basis. NRC management holds an annual meeting to (1) discuss any significant performance issues identified at specific plants and (2) analyze the overall results of its inspection and performance indicator programs and compare them with other industrycollected and reported performance data. NRC program officials said that if they identified any negative trends or inconsistencies, they would take action to better understand and address the cause.

GENESIS OF TRIBAL MYTH --1997

In shaping a picture of the NRC for Congress, the General Accounting Office, in its 1997 report: GAO/RCED-97-145, May 30, 1997, stated: Determining the safety of plants is difficult because NRC does not precisely define it. Instead, NRC presumes that nuclear plants are safe if they operate within their approved designs (design basis) and meet NRC's regulations. However, NRC's regulations and other guidance do not provide either the licensees or the public with the specific definitions and conditions that define the safety of a plant. As a result, NRC does not have an effective way to quantify the safety of plants that deviate from their approved designs or violate regulations. Determining a plant's safety condition is, therefore, a subjective judgment.

The GAO's 1997 statement about NRC and the definition of safety is off the mark, because it ignores the very basis of safety in the nuclear industry.


Rather than embody safety in the agency, or in a single static model imposed upon 103 plants, the licensing system has imposed a vast creative task individually on each licensee, prior to the granting of each license. The task involves the writing of a detailed Safety Analysis Report. The definition of safety, for that plant, is embodied in the Safety Analysis Report, a huge document running to ten or more volumes, with internal references to thousands of calculations stored elsewhere, and hundreds (if not thousands) of detailed design drawings, also stored elsewhere.It is known as the SAR, or (final) FSAR. So, defacto, the engineering designers who wrote the FSARs and the technical specifications have also written the safety standards, 103 differing safety standards for 103 plants. Each standard is extremely concrete, there is no vagueness. However each standard is huge, and there are 103 separate versions.


This kind of a document cannot be inspected casually, or cursorily by GAO, nor can operator compliance with it be casually determined by observing the NRC. To wrongly imply that NRC methods were lax, or "subjective" is a misleading and self serving statement, designed to lift the onus of comprehending the FSAR system, off the shoulders of the GAO team, and deposit GAO's unreadiness to prepare its inspectors onto NRC's doorstep, as a vague accusation of "subjectivity". With 103 versions of law, residing in 103 FSARs at 103 Nuclear plants, the amount and difficulty of material is just too great for GAO to assess, much less sum up. GAO failed to adequately comprehend this system, and wrongly reported it to Congress as an NRC shortfall. It is in point of fact, the defacto status of present regulatory law. As law, as a sitting legal structure, it ought not be mischaracterized as an administrative shortfall.



Perhaps if it understood its intended mission more completely, GAO might have proposed a new legal structure, complete with a general unified FSAR, but of course, it lacked the technical competency to even determine the nature of what it was assessing, and so could not have successfully replaced it with a more comprehensive upgrade. As it is, GAO has shuffled its feet unknowingly, at the periphery, accusing NRC of not safeguarding the public, when in fact it was GAO failing its mission, the mission to understand just where the concrete jot and tittle of nuclear safety was embodied--- in the FSARs and the tech specs, and not within NRC. This kind of a safety standard demands the dedication of a qualified set of resident inspectors, tasked with climbing the extremely steep learning curve in each FSAR, as a preparation for understanding how each individual plant is fulfilling its specific commitments to each FSAR. Once the subject matter is mastered, then the individual inspector, be he an NRC resident inspector, or a GAO inspector, can be ready to realistically compare plant performance parameters to the mammonth compendium of promised performance parameters, that is the FASR and The Technical Specifications. With such knowlege in hand, the judgement is not subjective. It is extremely objective. Meet tech specs=pass. Not meet tech specs= fail.



This is the American system. If it is monumentally complex, and thus not amenable to easy GAO mastery, that fact just makes any casual GAO suggestions made after a cursory look-see a lot less than enlightening. Therefore must Congress remain in the dark, and simply trust NRC? Perhaps, but better that they understand their own inpectors' blind spots. Therefore allow me to analyze the GAO assertion,line by line, in the light of what I've revealed above.


Determining the safety of plants is difficult because NRC does not precisely define it.
This is not true. Determining plant safety is difficult, because it is precisely defined 103 separate ways in 103 FSARs, and because each FSAR , with its accompanying references may take a year or more for a talented individual to comprehend.



NRC presumes that nuclear plants are safe if they operate within their approved designs and meet NRC's regulations.
This is true, but is not a shortfall. The vast system of redundant safeguards embodied in each FSAR provides large margins of safety, and its initial approval came only after detailed critical evaluation to the best scientific/engineering standards. Such trust is not ill-founded trust.



However, NRC's regulations and other guidance do not provide either the licensees or the public with the specific definitions and conditions that define the safety of a plant.
This is not true. The Technical specifications provide an absolutely precise and objective standard to the licensees, and to NRC. Perhaps GAO is suggesting a tech spec primer series be prepared for public consumption along the lines of "A nuclear plant is safe, when its tech specs are met", with explanations. I doubt if the public would be interested. GAO, on a mission to find the tech specs, missed them entirely, and now it reports that NRC has none. Would the public do any better?



As a result, NRC does not have an effective way to quantify the safety of plants that deviate from their approved designs or violate regulations.
This might have been germaine in 1997. In 2007 it is not true. The Reactor Oversight Process is now in place, giving objective banded scoring to each plant, in all major areas. Note that this statement is not about safety per se, but rather it is about the reporting of safety conditions to the general public.



Determining a plant's safety condition is, therefore, a subjective judgment.
This was not true in 1997, and it is most certainly nonsense in 2007.



In missing the absolute inflexibility of the tech specs, and by looking in the wrong place for the exactitude (looking within NRC, rather than in the license), GAO overlooked the very concrete methodology for maintaining plant safety, as being non-existent. This failure has now propagated itself outward through the Congress, and the public, as a tribal myth, wrongly accusing NRC of laxity.

THE KNOLLSFISH THEOREM

The Knollsfish Theorem

Four Hudson River fish testing strontium-positive were caught 30 miles north of Indian Point. What's up there, to make fish contaminated ? A man named Jack Shannon has a lot to say about corruption at the Navy's Knolls Atomic Power Lab, directly on the Erie Canal at West Milton New York. Check out http://www.mindspring.com/~kapl/index.html. He even gives a telephone number 518-587-3245. Another Knolls website is: http://www.globalsecurity.org/wmd/facility/knolls_k.htm.

One surmise I make is that work done under military aegis, can legally omit safeguards, under the rubric of national security. Shannon says much about this. Apparently Knolls dumped a lot of stuff, willy-nilly. Shannon was pursued, and fired from the Knolls Kesselring installation for blowing the whistle on it. Most likely, compared to Knolls, Indian Point is a virgin, pure as the driven snow. Most likely, estuarian damage from Kesselring far outstrips any imagined damage from the beseiged and minutely-watched Indian Point.

Very possibly, Entergy's mysterious fish test has outed the Hudson's covert radioactive polluter, Bechtel, operators of Knolls/Kesselring. The location of the 4 "hot" fish would strongly suggest this. If true, the green community would owe a strong debt of gratitude to the proactive Entergy corporation, instigators of the fish test, for bringing this abuse to light.

It is interesting to note that Knolls is not mentioned by congress people stridently demanding various concessions from Indian Point. Knolls is well upstream of Indian Point, and if Mr. Shannon's very detailed laundry list of dumped carcinogens, actinides, and radioactive junk at Knolls is even remotely accurate, Knolls and its leach fields are non-point-sourcing a heady weapons-of-mass-destruction cocktail directly into America's first river in full view of a silent John Hall, Maurice Hinchey, Nita Lowey, and Hillary Clinton.

What gives, honorable representatives?

How about an Independent Safety Assessment of Kesselring?

INDEPENDENT SAFETY INQUISITION PHOTOS !

ANGEL MORONI REVEALING TO JOHN HALL THAT INDIAN POINT NEEDS AN INDEPENDENT SAFETY ASSESSMENT

After a long Orleans road trip in 1978, John was awakened from his cannabis dream by a piercing white light, and a heavenly voice saying to him in ethereal tones: "G e t _ a _ b e t t e r _ g i g !"......"J o h n !"........"G e t_ a _ b e t t e r _ g i g !"..... "D o_ s o m e _ a n t i-s o m e t h i n g_ c o n c e r t s_ ,_ J o h n !" It was the middle aged angel of middle aged rockers (Bony) Moroni.

JOHN KNEW IMMEDIATELY HE WOULD FORVER BE "ANTI" --It was just against WHAT that troubled him!

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ENTERGY HAVING ITS POCKETS EMPTIED BY SPITZER INQUISITORS
Governor Spitzer today vowed to make electricity rates "As high as the people can stand"... by raising the anti on national guard troops sent to Indian Point to do guard duty. Despite the fact that these servicemen are paid from the Federal dime, Spitzer wishes to monetize this function, because attacking Indian Point seems to be in vogue with New York left leaning dilletantes having more than 3 million in the bank---Like Spitzer! Next Spitzer intends to impose a "Voting Booth Fee"--- of $50, not imposed since Jim Crow in the South 60 years ago. "We have to get money somewhere" Spitzer quipped, while eating escargot, and sipping chardonnay.

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WESTCHESTER BOARD OF LEGISLATORS LISTENING TO A LONG MIKE KAPLOWITZ HARANGUE, URGING AN ISA
The spineless "legislators" (here seen in the dunce caps), are being trained by Mike "Kapo" Kaplowitz to respond to verbal stimuli, kind of like Pavlov's dogs. His "dog trainer" , Tom Abinanti, is seen holding the punishment stick, on the left. The legislators are being forced to vote in a bloc on a series of nonsense issues, to demonstrate their Kapo's herding abilities. The rest of the people in the hall are disgruntled real estate clients that Kaplowitz has bilked, waiting for a chance at the mike to complain.
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STRINGENT TEST OF ROTATING MACHINERY AT INDIAN POINT INDEPENDENT SAFETY ASSESSMENT.
A rotating "nuclear Strapado" device is tested out by Hillary Clinton minions, on an NRC worker, seen bound and disrobed. The worker will be roasted above the fire, until a false confession is elicited, which will be written down and immediately sent to all progressive news outlets. This will form the basis of Hillary's new legislation, a call for an "Independent Spanish Inquisiition" , a stringent, piercing test, to be applied to any victim Hil thinks she can get away with it on, and besides Bill used to LOVE watching these kinds of S/M tapes while governor of Arkansas!
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NEW AG CUOMO PRACTICES HIS NEW ETHICAL METHODS--- HERE SEEN INTERROGATING A KENNEDY LACKEY, ON CUOMO JUNIOR'S EX-WIFE'S CURRENT WHEREABOUTS

The angry Attorney General is seen hanging Patrick J. O'McGillicutty, Hyannisport whiskey-butler and Kennedy party-girl procurer, thought to know just why the Kennedy-Cuomo liaison never worked. O' McGillicutty is seen exhausted , just after screaming out in pain "Bejeezus man, I can't help the wench if she can't cook friggin macaroni!"

HOW CAN WE DETERMINE THE TRUTH?

Truth or Dare in Public Affairs... The "IDK"

What we need is good old keelhauling.

As long as the "Gang-of-Democrats" is proposing obsolete "Trial-by-Combat" methods of finding out whether their staffs have been lying to them for years, I suggest we reach back into the American Nautical past, and revive another obsolete method of examination, the good old keelhaul. (no- not the "Independent Safety Assessment"---sorry!)

If John Hall's chief of staff can be tied to a rope, and dragged beneath the intake ports of Indian Point at high tide, he can undoubtedly either uncover whatever hidden evils are down there with the zebra mussels, or , if he finds just Hudson River Goodyears down below, perhaps the time "below the surface" can motivate him to own up to not really believing 100% of the exaggerated scare stories about Indian Point, after all.

Either way, the public can be reassured, and widespread public concern that they were being shined-on by professional Chicken Little-ists can be finally and definitively be proven either right or wrong, by a different examination crew, and a different method, much deeper and more stringent than is habitually applied to political press agents.

Therefore it is with great solicitude for public sensibilities, and the expressed wishes of millions that their electric bills not be arbitrarily tripled, that I declare a RISING TIDE OF MOMENTUM for an Independent Democratic Keelhauling, ( ..an IDK...) to be held each week at the Indian Point dock, until the truth is finally brought to light (or all the Anti-Nuclear Democratic politicians quit, and go to live in Bahamas, near Anna Nicole's old place).

At any rate , tapes of the "IDK" will become collector's items, as well known demi-celebrity press-hacks puke, and grovel, admitting they had contempt for the American public for decades---( until the definitive "IDK").

John Hall gets led, spouts anarchist line: "ISA"

Who said there would be lifeboats?

The 20-odd million people living in the soon-to-be-unaffordable Hudson Valley region need more than empty stunts, cooked up by devious and overanxious "activist advocates'" (paid press agents), in the pay of big charity, big oil, and antinuclear lobbyist foundations, and in turn, foisted on clueless Democratic electees as panaceas, without understanding, without any need, and in the end, without any possible viable result.

It seems that the paid antinuke lobby has settled on the "Independent Safety Assessment" as the next in a line of ostensibly serious proposals that all end up useless exercises in partisan attack futility. It is one thing to oppose policy from the sidelines, but it is quite another to be elected, and have the responsibility of making livable lives for your constituents, outside of any one-sided expectations on the part of the far right, the far left, or the far anti-nuclear fringe.

Just as bungled electric service negotiations are turning into major permanent rate hikes and tax hikes for the unfortunates living in Rockland county, are we to stand by mesmerized, while the same electoral stupidity begins to destroy infrastructure on the east shore, in attacking Indian Point power plant for no demonstrable reason, except that certain fringe political groups voted a "no nukes" line?

The no-nukes cadre was but a small minority in a fairly close majority voting Sue Kelly into retirement in favor of John Hall, and Hall made much of declaring he was "everyone's congressman"---- so now we demand to hear exactly what cause there is to begin to harrass Indian Point, and its mentor, Entergy, aside from promises perhaps rashly made at fuzzy-logic no-nukes concerts over twenty years, by a man who does not understand the area's big cities, the inner suburbs, the local job markets, the local near-suburban housing crunch, the need for blue collar work, and the urgency of the viable absorption of unknown tens of thousands of new arrivals, who are here for the long haul, and who cannot survive integration into American life as penniless marginalized peons, prevented from participation by ill-thought-out infrastructure-burning rampages, hatched in the name of 1980's rock'n'roll concert talk.

In the only other "Independent Safety Assessment" ever held, (Maine Yankee 1996) there seemed to be a glaring proximate cause---a smoking gun--- in an employee allegation of criminal wrongdoing. Without that allegation, which also implicated the NRC, no ISA ever would have happened a decade ago. Where is today's smoking gun? Where is the specific wrongdoing. It is much more than claiming Indian Point could be "Guilty until proven innocent", ..... it is a case in which our freshman congressrocker cannot even say WHAT Indian Point might be guilty of!

In the Maine case, in 1996, even the smoking gun claims were later found to be not true--- it just so happened that Maine Yankee was decrepit, understaffed, lax in almost every way, ignored by its corporate owners, and so it was put to a just and deserving death. And in the irony of ironies, the savior corporation called upon to send knowledgeable experts to Maine to complete the burial arrangements, was you guessed it--ENTERGY!! Entergy uncovered a host of FURTHER bad stuff at Maine Yankee, and correctly advised them to stay closed, and give up their license (which they eventually did).

At least in part from the glaring lessons learned in doing away with Maine Yankee, Entergy entered New York in 2000 with a healthy skepticism toward Indian Point, and began a long 7 year improvement plan, one still being followed today. Almost every area concentrated on by Entergy at Indian Point harks back at least in part to some laxity found at Maine Yankee, and therefore has been specifically targeted now for at least 7 years of ISA remediation at the New York plants, whether they needed it or not.

All this info is available to Hall, and tells him not only could nothing bad be found by an Indian Point ISA, but that it is at root a deception of the public, to act as if an ISA could do the public any good . It cannot. But it can help Hall, and a few other complicit cross-burners, because professionally organized antinuke fakery contributed at least some votes to all of them.

Bread & Circuses is, I'm afraid not enough here. What we need, all us 20 million forgotten souls (all of us who didn't meet at the concerts)-- what we need, is a concrete plan to build energy centers. Not study centers, actual viable electricity-producing power plants, to replace Indian Point's 2000+ megawatts, get them built, set up, and pumping on the grid--so that we can live here---- and I will be the first one to say , at that point, to Indian Point :....."Goodnight old gal, thanks for a fine half-century"

If nobody builds those plants, every single swipe at Indian Point , is a hatchet swipe on at least 15 million of us being able to afford to live here.
Mark my words. Its smoke and mirrors. Its bread & circuses. It's screw-your brother for a soundbite, but it is NOT responsible leadership.

It's like blowing up the Titanic first, so it won't hit an iceberg, and,
once in the icy water saying: "Lifeboats?"
"Who said there would be lifeboats?"

Why So Quiet?

In 1995 a whistle blower wrote to the Union of Concerned Scientists, alleging that he had participated in the falsification of computer code at Maine Yankee atomic power plant, in order to gain an undeserved power uprate at that plant. The utmost seriousness of the crime he alleged, and the lack of its detection by the NRC (who had granted the uprate), called into question the honesty and/or criminality of Maine Yankee's management, and the competency and/or complicity of the NRC as an organization, and did it all very credibly, from inside the fence.

A public allegation of a specific criminal act so serious had to be addressed, quickly, and in the most high-level fashion.That is why NRC immediately revoked Maine Yankee's uprate, and did an Independent Safety Assessment there.

The inspection done was a duplicate of NRC's usual inspections, and was "independent" only in the fact that inspectors from other NRC regions made up the team of 25 inspectors (not the previous Maine Yankee residents), and a small group of state inspectors sat in with the NRC team.

Unfortunately for Maine Yankee, and its ultra-thrifty parent company, a host of unacceptable conditions, and license deviations was found by the team, which would have challenged the plant's parent company to spend a lot of cash to fix things up. Two months after the report was issued Maine Yankee ceased operation.

After reading the report, and a host of other documents about the ISA, I have concluded that Maine Yankee, as a situation, and as a plant, bears no resemblance whatsoever to Entergy's Indian Point plant in Buchanan New York.

Maine Atomic corporation was cheap, ignored the plant, held back needed funds, never fixed anything, was short of staff, allowed fakery and evasion in its codes, as long as profits were made. Long-term bad conditions were tolerated so long they were forgotten, and when NRC came in, they were glaringly easily found. The Maine Yankee ISA was needed, and did a decent job. Maine Yankee should have been radically fixed, or shut down. In keeping with its cheapness and lack of faith in itself, Maine Atomic chose to fold.

On the other hand......
Entergy corporation, an organization suffused with belief in America's nuclear future, has undergone a steady series of improvements at Indian Point since 2001, improving not only items that Maine Yankee forgot about, but many others, also.Most importantly, no whistleblower allegation similar to the Maine Yankee false-computer-code allegation, has ever been made at Indian Point, and so...... no immediate prima facia reason, or rationale exists for an independent safety assessment in New York. Entergy's Buchanan plant is not understaffed, as was Maine Yankee, Entergy is not intent only on bleeding profits, as was Maine Atomic, Indian Point's design basis has just undergone a five year $40 million dollar revamp, its testing program is fully certified, its material condition is excellent, there are a minimum of operator burdens and workarounds, backlogs are way down, and the plant has a full complement of system engineers (Maine atomic did not believe in system engineers, never hired any, and so no individual champions ever existed for out of whack plant systems). Entergy has a full complement of system engineers. Every single thing that was bad at Maine Yankee, is exceptionally good at Indian Point. Indian Point's Cable separation and Reactor Protection systems have just undergone exhaustive five year detailed inspections, leading to major upgrades.-- these areas were ignored and completely deficient in Maine. Inspectors in Maine found a wire to start its safety pumps was glaringly not even attached. All these systems are newly inspected at Buchanan.

Researching all this has only reinforced how little our politicians know about today's nuclear power industry, especially the Entergy fleet, which in almost every way is the exact opposite of Maine Yankee, and an exemplar of every good quality Maine Atomic Corporation never bothered to achieve. Almost every single shortfall in the Maine Yankee Independent Safety Inspection is in some area that Entergy has addressed previously and vigorously at its Indian Point plant, and thus pre-improved to far beyond what Maine Yankee could have attained, even if its corporation had stayed the course.

It's more than apples and oranges.
It's worm-eaten rotten Maine apples versus fresh golden Indian Point Oranges.

Anti-nuclear press agentry shops have hung their hat on the supposition that something must be wrong at Indian Point, because they want something to be wrong. Unfortunately for that supposition, Entergy got there the firstest, with the mostest, and more or less started their own, internally motivated Independent Safety Assessment in concert with their purchase, beginning over 7 long years ago. The sum total of the very exhaustive, near-complete round of multimillion dollar improvements adds up to a firm, valuable local infrastructure resource, a gem in New York State's energy crown, and a wanted, valued business linchpin, upholding the local area's wellbeing, in ways that talking head activism cannot ever replace, and does not intend to.

Those calling for an independent assessment might more productively assess the source of their negatively-spun misinformation, and the self-inflating claims of those who stand to gain from the notoriety attached to false accusation. That way at least, they will have something to find, and our lights can stay on.

Why so quiet?
Nothing's wrong.