ML020180417

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M. Mulligan E-mail Dated 1/4/02 Re Additional 2.206 for Vermont Yankee
ML020180417
Person / Time
Site: Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date: 01/04/2002
From: Mulligan M
- No Known Affiliation
To: Victor Dricks
Office of Public Affairs
References
-RFPFR, 2.206
Download: ML020180417 (12)


Text

Robert Pulsiter - Additional 2.206 for Vermont Yankee Page 1 From: "Michael Mulligan" <steamshovel @adelphia.net>

To: "Victor Dricks" <vld@nrc.gov>

Date: 1/4/02 7:50AM

Subject:

Additional 2.206 for Vermont Yankee Mr. William D Travers Executive Director for Operations United States Nuclear Regulatory Commission Washington, DC 20555-0001

Dear Mr. Travers:

I am respectfully requesting an additional 10 CFR 2.206 on Vermont Yankee. I believe there has been a systemic failure with the NRC in administrating the Licensing Amendment changes of Vermont Yankee and the rest of the industry over the years. I believe that the licensing Amendment wording says one thing to the public, with Vermont Yankee and the NRC basing the changes on some yet unseen process and rules. Fundamentally the public notification and explanation of the changes, and' risks, are not accurately represented in the wording of the amendment change.

I was going to put the total number of licensing amendment Adams entries from Limerick, LaSalle, and Vermont Yankee of 2001- but the site was down in the last few days. I got on the site and I've gotten a better idea. Actually, access to Adams you can get to most times.

The total entry numbers of Adams for the year of: 2001, 2000, and 1999 are (46,653), (51,763), and (16,214). The total entries with the word "amendment' are: (8467), (6045), and (1341). The percentages of amendments to total entries of that year are 18.1%, 11.1 %, and 8%. Did I get that right; you had a 40%

increase in entries with the word of amendments through the year of 2001-from the year of 2000. You will notice that the total entries for 2001 had decreased from the year before, and there was an increase of amendments in 2001. Note: I am counting both nuclear plant and other types of nuclear licensing entities.

1.. I request that Vermont Yankee be immediately shutdown.

2.. Seeing how the public has no meaningful way of assurance that all licensing amendment changes have conformed to plant design and licensing- this plant may be configured in a way that is very unsafe. I request that all licensing amendment changes wording conform to, and accurately represent, the hidden system of the agency.

3.. I request that any significant off normal event such as in the Vermont Yankee summertime torus cooling (other examples: Limerick relief, LaSalle suppression cooling and SRV leakage), be publicly analyzed, and rationalesbe comprehensively publicly documented as in the multi- safety criteria of license amendment 248(reduntant equipment). I request that the document be submitted prior to the seasonal issue (yearly) if possible or monthly as in the relief's. That all know potential active degradation and deficiencies, system interactions (SRV), propensity of interrelated systems to approach temperatures limits, (rivers temperature and Dam pooling) the listing of the historic record of the shortcoming, the running opinion of equipment times, be publicly evaluated and included in this document.

And just so that nobody misunderstands. This issue is bigger than Limerick, LaSalle, and Vermont Yankee. What I am trying to reflect here is- how over-regulation gets born in the industry. Thank you for giving me all the ingredients at this moment.

You have these prolonged operational irregularities that leads to an accident that you couldn't predict. In Attachment 3

Page 2 Robert Pulsifer - Additional 2.206 for Vermont Yankee many cases, the accident happened earlier, but you make believe that it will never happened again, and it happenes again. Then you sit again with similar irregularities. You bureaucratically try to hide them- or they seem hidden by the outsiders-you make it difficult for the public to understand what is going on with the irregularities. The hiding of these irregularities, the surprise of an unpredicted event happening again, the arrogance of all you people thinking that this is what the public wants and what you think you can get away with it, creates the beginnings of mistrust. Then there is the feeling of irregularities breeding the acceptance of more irregularities, with everyone fearing that the system can't differentiate the razor line between off normal events and accidents. These are the ingredients of runaway mistrust, and are the genesis to over regulation and licensee burdens.

So the question becomes, how do you create a bureaucratic system of transparency and public disclosure? Just making these issues transparent forces them into a behavior change. You shouldn't let these officials make these kinds of decisions behind closed doors. The whole game will be about the self-interest of the officials.

Free Will We defy augury. There's a special providence in the fall of a sparrow. If it be now, 'tis not to come. If it be not to come, it will be now. If it be not now, yet it will come. The readiness is all.

William Shakespeare (1564-1616), English dramatist, poet. Hamlet, in Hamlet, act 5, sc. 2, responding to Horatio's offer to forestall Hamlet's duel with Laertes, of which Hamlet has a premonition that all is not well.

South Texas unit one; Initial delicate plant cooling water design and maintenance- letter of mine on 10/10/01 and the special inspection of essential cooling water vulnerabilities from Dec 18, 2001 Are we really facing an American energy taliban? My friends, this primitive, and at the same time, ultra modern cabal of medieval power brokers, has stolen your future and choice of energy.

They are dictating global energy policy. These guys are hard wired up to computers of enormous capacity and power, and at the same time they want you to live in a world of a hundred years ago. They steal your future by these computers in a fraction of a second, in a blink of an eye, in debts for no electricity, and they extract profit at multi points in the energy delivery. Natural gas, coal, electric power plants, long term and short energy futures, the transmission of electricity and natural gas, financing, the exclusive trading of all of the above; these huge corporation owns a substantial strategic subsidy in every part of profit extraction stream. They yank and pull, create shortages and over-production, the collude, they created instability at strategic points of the sector, and they use their insider knowledge, position, their economic and financial weight, and their use their political connections to place themselves on the elite side on the ledger. These people have designed a terrible unfair system.

The politicians, the regulators, the federal government, the state governments, many nations of the world, are all involved in this nasty system. They all have in common the necessity, and camaraderie, of maintaining control and cost of energy, such that they are elevated into a superior class of global citizen.

This is what the global income disparity between rich and poor bring always brings about. In many ways it's not a closely coupled brotherhood of thugs and grand global conspiracy, but what these people have in common is their conspiracy of self-interest.

What these people have in common too, is as the world comes down crashing down around us they continually portray in the media of the good life, and that opportunity is right around the corner. In the

Robert Pulsifer - Additional 2.206 for Vermont Yankee Page 3 greatest economic bubble of this world, they have always said that your recovery is right around the corner if you were only educated, if you came from my good school, if you came from the great neighborhood, if you were my color, if you were in my religion, if you had my patriotism, if you came from my low income housing project, if you had my government belief, if you had my superior position, if you was as hurt as much as we were, you could be in this elite group as we are. You could be the gatekeepers as we that keeps the multitudes at bay. They will tell you that you are not just putting in enough effort. They will say you need to put your self-interest and our self-interest of this special group above all your sister and brothers. He who owns the most gold wins. He who owns the power of terror wins. He who owns the power of your good life wins. These people always know where that exclusive golden exit doors are too.

If you look carefully, many sectors of the global economy is similarly situated. Throughout the world today there is very little competition between equals anymore. It all about market share, mergers and profits, and the availability of the Mega Corporations to play off one class of the world's community against another.

My friends, the majorityy of us our in the race to the bottom, and they are in the race to the top.

As for the NRC, we sit in an indescribable system of processes and rules that only the high Omar of nuclear can understand. The utilities and the NRC have legions of lawyers and specially trained employees with mental beards, who make these mindless rules, and get around the rules. The scale of justice here weights is to reduce the burden of regulation for the utilities and increase the process burdens to the citizen. You have to be an extraordinarily skilled professional to be able to occasionally access fairness in the system. Most of the times, the issue brought to the system is deemed incorrect because you violated some rule, didn't understand some of the processes, or weren't granted transparency.

The officials never wants an outsider to take or to be given credit for anything. That is the reason information is so control within the industry. They always strive to be the authors and foundation of authenticity to anybody outside the system. These officials authenticate their self-interested facts and de-authenticate any facts of question. You will notice that they say they are the only ones with the verifiable facts. They will say the outsider just doesn't know the facts. They are mostly right, because they spend an enormous amount of resources so that information is restricted to the public.

As for help in navigating the system, congress didn't mandate that the NRC should help the citizens go through the NRC's mind numbing madness. You know, it sounds like that if one of these officials seen a "little old lady" fallen over near her front porch, they wouldn't help her because congress and the corporation didn't explicitly authorize it in the policy, budget and the rules. They would have to get a gaggle of experts, lawyers, and months, to figure out if they could help that old woman. And don't you forget they would need the corporation permission too. And if that little old lady had a complaint, and especially if she showed some intelligence, they role right over her with their stoic bureaucratic fagade. The NRC only serves the corporations and the laws that were bought. This shouldn't be a surprise to anyone in the ways of money and power of Washington.

You might as well wear a burka in covering your head in trying to get the American energy taliban to understand your concerns. The NRC processes as an example of this doen't ask questions in the petition process, so they can intentionally misrepresent your concerns within their refusal. They want to give as little information out as possible, and of these officials, the corporations, need to remain off the record.

You only got 10 minute to talk! You know for a fact that their silly rules of the process are designed for the needs of the corporation- so that they can misrepresent any issue that pleases them and kick you concerns out of the system before you can get them to explain the system on paper.

These extremists believe in an impenetrable theology and religion of nuclear energy, and energy as a whole, with their superiority. They believe really, in the religion of their hyper self-interest. More worrisome, is they have conned themselves into believing that their self interest, and their interest within the corporation/agency, is absolutely patriotic and in the county's best interest. They believe that if public deception is allowed in the form of regulatory policy and congressional laws that this public disconnect is perfectly patriotic.

In other words, as in Enron, "their self-interest" of power, position, money, bonuses, stock prices, access

Robert Pulsifer - Additional 2.206 for Vermont Yankee Page 4 to government, governmental programs, the form of governmental regulations, your access to government, exclusivity, influence with government, anti-transparency, is worldly altruistic and profoundly patriotic. They think, they know what in your best interest, that you remain ignorant, and that the world serves them unquestionable.

Many in the industry have an absolute belief in their beliefs, and a belief that they know more than the public. They are in control of the impenetrable engineering theology of safety, they make the rules, they intrepid the rules for themselves, and they ignore them when the please. The NRC officials think their industry is more patriotic than all others, that the industry is singularly vital to the future of this country, and that the nuclear industry and the NRC have superior knowledge. They think they are smarter than you are and it's in your best interest that they control information. They are fighting a war for you and your truth is their enemy. They teach the new generation that individual economic self-interest is the new religion. They believe the world serves them.

You have an aging industry that is controlling the information to you. There is a dangerous mixture of increasing troubles in the industry. There is super patriotism and elitism, whose aim is to hide information from the public. They are using the fruits of terrorism to withdrawal information. Democracy, as it pertains to managing our energy choices is in disarray, as a result of the scandal of campaign contributions. The mixture of these crisis all leads to the point that the elite's of us who are suppose to be managing our energy sector, are in complete disarray. There is a power vacuum and that the rest of the minions now think they are in a position that they know what best for you. They can deceive, lie, distort, withhold, and it's all in the worlds and country's best interest.

My friend's fascism flourishes in disharmony, destabilization, and disarray. It begins in a power vacuum. If feeds off the widespread instability of economic disorganization and wide-ass crazy economic theories that benefit the elite's, and de-legitimatizes the aspiration of the multitudes. This breeds injustice and sews the seeds of terrorism. They live in mansions of inhumanity and you pay the debts of their mistakes. They beg for the instability with their lies, they welcome the fresh blood of the innocent, they calculate the profits of their self-interest. The hammer of oppression seems to bring control to the spiraling crash that they created.

And what about me and you. Why do we have a need to believe in their distortions? Why do we feel better in their lies? We made this happen by our little actions, our sleeping, our needing advantage, our insecurities, and our intentional illusions and distortions. Why do we pick up that club against our brother?

Why do we think god loves our brother better than us?

I got an answer-at least for me. That if god, or the universe, or chance; when he show any favors to our bothers, that we think it is a zero sum game. You know it seems we could have every pleasure in this universe; and if we spied god giving a crumb of bread to one of our poor and broken brother, we would be jealous to no ends. What he gives to our brother he won't give to us? Why do we all play that game, if you don't observe my rules, god won't love you? What is up with this lesser god? Why did they teach me this?

At the heart of all of this is primitive instinctual need of self-interest and self-preservation. Self interest, self-preservation, self-aggrandizement, self promotion are the dominant management theme of the world today and it's virulent in the elite's for absolutely no logical reason. They are stealing the crumbs from the poor. These primitive instincts have allowed you to crawl out of the ocean and you can't get to the stars (or beyond) from there.

The primary responsibility of the NRC petition review board, or any NRC processes, is to protect the corporation and the industry. It is to bureaucratically make war on any outsider who challenges the status quo. It is a secrete war. Their highest responsibility is to figure out how to reject your petition.

They know that if you use your intelligence and force them to document what really the system "is"-the multitudes will get a choice on what the domestic energy philosophy will be of this country and the freedom to choose. If truth, if honesty, transparency and democracy, if it flourish in any energy sector, then it will happen across the board. They would all be in trouble then. There has been terrible evil that has been

Robert Pulsifer - Additional 2.206 tor Vermont YanKee Page 5 perpetrated against the public in the last decade of energy sector management. To tell the truth, would mean they would have to confront these errors within themselves, and it's not in their human nature, so they won't. It's not in their self-interest.

They think they know what's best for you like the Omar with the veil across your eyes. Of course they will let you choose, or give you the illusion of choice, if you will accept their short list of desert-dry aging sterilized facts. Obscuring your view, and hiding your attractive face is in the high priest theology of energy beliefs, a method to control the Omars attractiveness to you. They think, to obscure your vision, that they will regain control of their basic human needs and wants. It medieval insanity I tell you!

The veil of untransparency is really a signal to the elite's of your unworthiness to be engaged with the system. It is designed to prove that your place in life is to be submissive to the power that controls information- because you don't have the real inside story as they do. You never will, because they control the gate of the future. It is to make the Omar of the Commission, the Popes of the corporation, the dictators of finance, debts, and stocks, of the DOE, the president of the United States, to always seem superior to any legitimate challenges of the outsiders. They are in the inner room of the god of knowledge and energy that you will never be privy too. Their god only blesses them.

This is a story about domination, submission, and control of a national energy policy. It's about keeping you barefoot, pregnant, and uneducated, and out the information stream. You are forced to a sub-existence of dependence of there choosing. It's about them using your body for their own pleasure, the body of this country, and your children paying the price of living in sub existence for a generation. They have no idea of what a joy of a child is about. It's about your future of back breaking responsibility and poverty, and their fleeting temporary pleasures and their illusions of control. It's about the logic insanity of making you have a child that you know you can't feed and house, and them telling you god doesn't believe in birth control when they want you. It's about what role the public will play in energy policy formulation- will it be submissive.

This isn't about a few dollars a month in your electric bills. It isn't about creating stock price value in the energy sector. It has nothing to do with your 401k program. Matter of fact, you should give your present net worth, your future social security benefits, that pension, to the poor of the world. It's only when you have nothing left to lose that you want to change the world. You couldn't live with the injustices of the poor for one day.

Who said; sell all your possession and give the money to the poor-then come follow me if you want to enter the infinite universe of love? He clearly identified the past, the present, and the future. That is a breath-taking message of ever lasting truth. It isn't that wealth or possessions are dirty and unworthy. He said we get wrapped up in the illusions of short term self interest with our temporary and illusionary wealth.

It is absolutely contrary to your the real interest of living a happy and fulfilled sacred life. The illusion allows you to live in a mansion and leave millions of kids dying of starvation.

This sets up the global system of wealth disparity. It sets up centuries of conflict, terror, strife, and technical stagnation. You waste you time in educating for war and it limits your technical advancement by investing in war machines. Your young men and women ride around in these war machines and witness the horrors of this world, and the best you can say about it when they come back is that "you have no idea how well off we compared to the rest of the world".

It all about self-interest, separating the haves from the have-nots. Many of your own children have given up on you and are on a self-disruptive binge that you will end up regretting. There is more poverty in the hearts of American children than in the third world children who are dying of hunger. My children are dying all over the world and at an increasing rate. My children are homeless and hungry all over your streets. My children are killing themselves in your schools. My children are losing themselves to the ideology of violence and I can see for generations out. My children lead lives of subtle and not so subtle suicidal rages. My children have lost hope in learning.

Everyone one of these children I can hear there disparate, at times panic stricken, and sometime quite

Robert Pulsifer - Additional 2.206 for Vermont Yankee -Page 6-last breaths. Oh, these poor innocent souls go out quietly. I counted every breath in their poverty and terror stricken lives. I will be there to welcome them back to the life of everlasting love. Those magnificent souls bared witness, and memory, to the appalling neglect of your years.

In every child in this world, your are creating the ingredients of individual instability. You are building more laws, munitions, police, prisons and the militaries, to jail, to punish, to kill, a small percentage of us so that the rest of us would remain in control of ourselves as a result of your increasing systemic instability and insanity. These troubles are also reflected in the silent majority of of individuals who do not visit you jails.

With an increase of your children's instabilities, you are guarantying that the world's governments, businesses and systems, will mis-function in the future. You repeat your mistakes over and over again.

You measure the results and ignore them.

Don't you for one moment feel proud of your civilizations technical and moral advancement? You should have an efficient low cost energy system throughout the world by now. It should have almost unlimited capacity and disconnected from effecting the weather. You should be able to move freely throughout the world without traffic gridlocks. You should have been past that insanity of waiting. You should have developed the organization to manage the disparate peoples of the world.

All of my people should be able to do as they please. In my world, to do as you please, means to love you neighbor as you would yourself. It is not my rule. It is not a primitive instinct. It's just the way this whole thing works best. It is the distillation of knowledge of all that was ever was.

Every one of my children should feel safe by now, should be housed, fed, educated, and mostly loved.

Loved most of all. And no traffic lights! All of these kids of the world having a diverse education that celebrates all your similarities and differences and should to be available to everyone. Do you have any idea where you would be if, all your children of the world were educated? All you people would be busy building the better world, instead of building strife and wars. You would all be better at the agreeing to building the roads, managing growth, have environmental off-sets, having very little stop lights, less time in frustration, and enjoying your ride. Don't laugh at your transportation problems, it's causing enormous unnecessary frustration and anger.

This strife, anger, disorganization, ignorance, your isolation from each other, the wastefulness, your stories you come up with to explain it, your lying to each other, would be significantly reduced. You could change it all right now.

All of you, concentrating on you self interest, is driving you to this. It's not that you won't have any challenges and dramas within this stabilization. Quite the contrary! It would allow you focus on our problems, solve them, and build the technological solutions to societies. You guys are carrying around a ton of unnecessary weight. You would trust your lawyers, scientist and businesses again! You would see starling progress and it would feed on itself. It's your choice.

Let me tell you something straight, this world comes up short in a lot of ways. The way you manage energy is a big shortcoming. If you could only see? You are blinded. You should be visiting the stars by now.

The management chaos of your energy systems today reflects your primitive civilization. It's going backwards. The massive growing instability of energy production, distribution, and usage worldwide is reflective of the global insanity. The more you have, the more you fight over. You think you can create global organization and stabilization with the management themes of "what's good for the few us", the very cream of the crop, is good for the world.

Can't you see that people dying? Many of the adults live in a world of no hope. Can't you work this out to predict the future from what you measure? You people are of proud the facts from of what you can selectively measure. What most amazing is you vast system of denial. I recently gave to you the "world at your fingertips", and you are still blind. Blinder than one hundred years ago.

Robert Pulsifer - Additional 2.206 for Vermont Yankee Page 7 You can stick your chest out and wave your flags all you want. This isn't about extensively shutting down Vermont Yankee or any plant. It isn't about what you can't do, it's about what you could do. You have no restrictions. It's about organizing the world into a cohesive unit. Let's have big goals. Worthy of who we really are. Each one of us is bigger than we think, bigger that our history, bigger than our education, bigger than what anybody can prove, and mush bigger than any mistake. It about reordering this world.

Let's talk a little about staying with the facts. All your engineering facts, your documents, what you can prove, the laws of gravitation, the half-life of your radionuclides, the speed of light, the maxium bandwidth of data that you can communicate across, your organization of such; are just a tenuous scratching of the surface of what truth and love is really about. If you made a mechanicalistic calculation, used the best computers to predict of what your future is going to be like, and based it on the totality of the present facts, you would find no hope. You would find the horror of your movies and dreams. It you counted ever atom in this universe, you still couldn't figure it out.

I will tell you a secret. We counted all the atoms of the universe and beyond. We built that computer which can characterize all the material fact of this cosmos; of matter, energy, of time, distance; and space. Even our babes, knows that matter and energy in your universe are constantly in transformation, that units of energy continually gets added and taken away from the cosmos. At any instantaneous time (standard), we know the exact count of the atoms. Of course, all of the computational and the manipulation of all the absolute facts don't begin to explain the mysterious magnificence of the spirit.

You people are coming to the realization that there is more material in the universe that you can't detect, than what you can see. That's from sub-atomic's to the dark matter of the universe. You have not a clue of how illusionary your facts are. How you technologically measure the facts of your day, sounds to us like your ancient fathers words in trying to express their facts of two milleniums ago, on the shape of the earth, and what was going on with that sun and moon. Oh, they were sure of their facts, and the elite's were surer still.

Ever particle of the universe, we wired them to each other in real instantaneous time. Our computers are connected to everything and are absolutely amazing. Figure out how fast that baby is. It knows the past, present, future, and it knows what absolute creativity can do at any point of measurement. Actually, we cheat a little. Of course we sit outside the natural laws, as you see them. Our computers really doesn't contain any material at all. You could explain it better as a figment of your imagination. In days past, they expressed it as the collective conscience.

Are you a satellite workstation for the network? Anyway, what about nuclear power? It's how we made you.

You are all broad-banded connected to our sacred computer. Love encompassed the knowledge of all that was, all that will be, and all that you don't know. We were geniuses. That modem connection can be as subtle as the barely perceivable whisper from the trees on a winter's windy day, or as the expectations in your mind of a flowering springtime. It is as profound as shaping the universe. You have the choice to do, and hear, what you please. You follow what love is in heart, and you have the knowledge of everything.

This planet is at the point of a startling transformation and evolution, of the type never seen before.

All of us are endowed with the facts of all the atoms and particles of the cosmos, a connection, to that which makes us up, and what does not. Maybe more so the memory of an illusionary material. All of us are parts of an astounding creative force; all equally connected, even the least of us, and even the less of us. Just who of us knows what truth is? I tell you, you know more of what you are not, than what you are.

The facts as we see it, is that you are love.

What this country stands for within democracy: public participation, the bare truth, and transparency, are unnecessary burdens to the NRC. I'll bet you if you ask the NRC, they will say within the open democratic principles of this country; that within risk informed regulatory philosophy; that our constitution and its astonishing meaning within our lives, creates less than insignificant safety enhancement within each plant.

Thus these universal ideals are not relevant in the world of the nuclear gods. That freedom and the free

Robert Pulsifer - Additional 2.206 for Vermont Yankee Page.88 Page human spirit are not cost effective to the utilities.

It is risk informed regulatory philosophy, where the safety of the nuclear plants is not the primary philosophical responsibility of this agency, and where the cost to the corporation and the unscrutinization of the agency is the highest priority. It's called the protection to the elite's income stream and power-independent of future national needs. We are facing the corporate control of government, where the corporations gain the use of governmental instruments of national secrecy, the fruits of terrorism, and nation security, as tools to monopolize our future energy needs and democracy itself. We have brought back the life of President Nixon!

Who hasn't noticed the increasing public fear of nuclear power? The public approval rating of nuclear power is plunging. It might more be the public is responding to the foolish talk of the agency, and corporations, in explaining the industry situation in this crisis.

The public is becoming increasing concerned of the disconnected talks of the officials- from the average lives and troubles of the multitudes. Are these elite's becoming disconnected to the hopes and aspirations of the majority? Are they beginning to talk in a language that the public can't understand- the language of the elite's? If truth were told, many times in history when the multitudes begin to loose confidence in the management by the elite's, the elite's begin to depend on the abusive tools of governmental instruments.

National security is their favorite word of power.

You can't help notice the plunging public approval rating of the nuclear sector. It's more reflective of the frozen and protected culture of those that has risen to the top of the industry. There are just not dynamic, revolutionary, and persuasive. They would rather abuse the instrument of governmental power to dictate public policy. Many times these men with small minds, when they lose their ability to persuade the crowd, they pick up the dirty tools of governmental oppression to accomplish the deeds.

It becomes a virtuous cycle with the corporations straining for control in times of instability- with it becoming a chain reaction of favors and protection between the politicians, the regulatory agencies, and the utilities. If you don't get it yet, this country has been in an unprecedented destabilization of the energy sector for the last decade-with the intensify of the decline increasing in the last few months.

The philosophical underpinning of the management by the elite's of electricity and energy; business, regulation, governmental management, and competition, has been nothing less than a object failure in the last decade. They have lost 100's of billions of dollars, tens of thousands of jobs, there is corporate wreckage spun throughout the country, there are unbelievable energy price spikes, there are energy shortage and massive surpluses, there is massive collusion and market power, we put on the books debts for the next twenty for power that we used yesterday.

We have lost the ability to transform our energy usage in the face of enormous world destabilization cause by Global Warming. It's a political failure of the elite's of astronomical proportion-with our kid going to feel the brunt of our craziness. With the emerging perceptions that the chickens are coming home to roost from their monopolized power political short circuit- they need massive amounts of abusive political power to maintain the corruption and public control.

You can't help see that with this plunging' public opinion of the sector, of the official's fear of their inability to connect effectively by their intelligence and persuasion, of what's best for the world and this country.

You can't help but not notice that these simple-minded officials who don't have the skills of public persuasion, of not having words of the poets and the great thinkers in our past history, that they default to Nixon-like apparatus of National insecurity and National interest. It begins to sound like it's in the national interest to protect the corporation and the Elite's- from the truth getting out to the public. It's a conspiracy of self-interest on a global scale.

Nothing more undermines national security and national unity in times of unprecedented crisis and war; than the government using external threats as an excuse to protect- and restrict damming information - of the corporations and the elite's. Would they rather save their bureaucratic and political careers-absorb

Robert Pulsifer - Additional 2.206 for Vermont Yankee Page 9 personnel humiliation-than to protect and save the heroic lives of those who are fighting on the front lines depravation, of public policy, terrorism, and war?

In a world that is burning up. In world that is beginning to understand how damaging of the weather extremes which is at undermining the lives of the world's poor and even effecting the highly advanced societies. In a world of water shortages and environmental catastrophes. In world of the extremes of the object poor and unimaginable wealth. In a world that is armed to the teeth and insecure. In a world of starving children and hopeless adult. In a world of energy destabization. In a world of killing, suffering, dying and death. In a world fighting for the resources of subsistence.

My friend if you can't see this world; the beautiful whole globe, that ball of night and day, of sunsets and sunrises, of blue oceans, of those amazing clouds of movements, of the brown, of the green, of snow, of the sounds of rain, of the sounds of the gurgling of our rivers and steams, of the songs of our birds, of the lights of our cities and the lines of our roads, of the gleeful playing of our children, of life and living. It has all come to a point of choice, of our moment of greatest challenger. A potential that sits outside the facts our past, and maybe our demise. If don't see the facts of what is in your heart now, then you will never see it. You have to choose this very moment or it too late.

Go sell you possessions and give the proceeds to the poor. Come follow me into ever lasting love. What I trying to say is you got to figure out a way to disconnect yourself from the anchors of materialism and self interest. If you can't figure out a way in you head-to free your spirit- then sell everything. Make everything worthless and the evolution of the world everything.

We are a culture who has been taught to be fixated on personnel success and in love with self-interest above any other ideal. Our politicians are us, and we revel in their illusionary self success. We live in big homes, with multi million dollar bonuses, and we deem this world successful because of our wealthy accomplishment; and we walk by a women who is in a ball shivering in a winter night because she has no place to sleep. We have not the slightest clue what universal and deep-seated success is yet in any of our lives today-from the richest of us, to our third world kids who are dying in the streets from lack of care.

President Johnson credibility gap became apparent when he began abusing the apparatus of government control to suppress the bad news for political gains. He was not above using the Vietnam crisis as a means to control domestic policy. Nobody, who has recently heard his recording of those times, can forget his angst over his choice of war, truth, communism, dominos, and personnel humiliation. He knew in the very early stage of the crisis that the war could never be won. His choice was to keep the war going that couldn't be won, killing thousands of Americans, or telling the truth and backing out of the war, and surely sacrificing his political career and our national credibility. . He said "It's like being in an airplane and I have to choose between crashing the plane or jumping out. I do not have a parachute." We seem to all be on that airplane now.

His choice was political self-interest and lying to the nation, and he guarantied the failure in Vietnam and his political career. The framework of his decision is what we all wanted at the time and we all paid a higher price than he did.

At one time or another we all try to massage the truth. We learn a lesson about the cost of not being truthful, forget the pain of it, and repeat the mistake all over again. The power to control information is so addicting. Why that is so, is because it works in the beginning. It feeds our ego in that we can leverage our position for nothing. You are caught up in the illusion that you can gain your goals, even if the goals are worthy of world good. I am not equating Afghanistan with Vietnam at all. I am telling you to be careful with trying to control the truth. Nobody can do it for very long. The truth guaranties national and world cohesiveness- untruth knights the concentration of power to the few- with the control of information fertilizing a chain reaction of divisiveness that you can't see, which lies beneath the iceberg.

Mostly me, and all of us humans make mistakes, uneducated decisions, errors, acts of commission or omission, we hide, we steal, corrupt, and kill, and in this folly of each of us, we can see the intrinsic language of the interconnections with us all. This humanness of us all, and the equal and opposite force of

roperi -'UiSlTer - /aalon[iOTd'a1*.Uo ror vermoni TaKee forgiveness; the forces of the infinite, the unmeasurable, the unquantifiable, the undocumented, the unexpected and undeserved, may be the most easily understood signal in the universe throughout time. Is it the god in each us.

We may be more humanly connected in the web of holy life by our folly, than by our fleeting successes.

For if unvarnished truth is really spoken here; then from the pope, to the President of the United States, to the NRC Commissioners, and to the little Brattleboro VT homeless bag lady whom I witnessed sleeping by the front door of Aims department store on this Saturday morning at 4AM, and all the people in between; then we surely must all understand the universal language of our mistakes.

To dream of a more perfect future, to dream of a better me and you; is to be more solidly connected to the absolute present. It is to be connected with the undocumented and the unmeasurable. It is to demand more of life and living throughout the world. It is to begin constructing that shinning city on the mountain, where everyone on this planet is fed the unvarnished truths of the present, has home, and is loved.

During the Vermont Yankee 10CFR2.206 of December 27, 2001, we fell upon a very serious national policy concern. I was discussing the wording of Technical Specification Proposed Change No.248 on the reduction of testing with redundant equipment. Basically, I was contrasting how Vermont Yankee in 248 was used as a justification that reducing testing would prevent unnecessary equipment wear and damage.

I was in amazement that the operation of torus cooling for non-safety reason was never analyzed as in the same safety categories as the 248. Torus cooling for non safety reasons is risk informed approved. I said the industry analyzes safety and risk in different ways- if it's going to give a utility benefit or it going to cost them. I asked what would be the quantified comparison of equipment hours saved from 248- to the running hours of non-safety equipment operation of torus cooling. And I was going to compare all the safety categories of 248 to summertime torus cooling.

Out of the blue the NRC petition director said -"who reads the license amendment wording"(recorded). He said the NRC doesn't use the License amendment wording as the engineering safety justification of the licensing change. He implied that it was only a potential licensing amendment- so that what was written by the utility doesn't matter. I guess the theory goes of the NRC, that a petitioner can't use the wording of a Vermont Yankee license change, because the NRC themselves don't pay any attention to the wording. He even mentioned that in the potential license amendment change, the NRC doesn't have any control on what the licensee writes, and he implied it would not be a matter of concern to the petition review board.

Like what is the failure rate of licensing amendments? George Orwell, are you there?

So if the NRC doesn't use the license amendment wording and explanation, who uses it. What is its use to con the public with phony words and processes? You mean the utility functionally explains to the public on what the license amendment means in the public document- and the NRC uses a hidden system, process and documents, to approve and justify the license change. You mean the utility can express gross safety philosophical error perceptions- with it not being a NRC concern, because the change is not based on the wording of the request. It's only a vehicle of public propaganda that doesn't have to represent accurately on what the risk is to the public.

On the potential or requested license change that hasn't been acted on yet by the NRC as in 248- you mean a utility can explained a grossly distorted safety philosophy in the future license change- with the NRC thinking it doesn't matter what corrupt safety language the utility uses. Is the NRC that afraid of the industry- with the commissioner so in the pocket of the CEO's, that there is shield set up by the agency, so that agency criticism is controlled. You mean an independent regulatory agency of our government has set up an widespread accepted governmental bureaucratic policy, whereby they speak in a special way to the ones they regulate, and a different way to the pubic, and another different way between themselves Let me tell you what we got here. Whether it's a slowly failing core emergency cooling device as in the Limerick safety relief valves, or unpatriotic public con job interpretation of the justification on how license amendment are granted, this agency is terrified with acting in real time to any plant crisis. You are terrified of critiquing the industry before an accident. Whether it's the shaded and shallow inspection report disclosure on why torus cooling was used this past summer, or hiding the fact of fuel failures at Vermont

Robert Pulsifer - Additional 2.206 for Vermont Yankee Page 11 Yankee, you have entered the arena of widespread public intentional deception. It has been going for many years.

I don't believe, as an agency, you can differentiate the deceptions from the truth anymore. And there has been prolonged high level political acceptance of this lying from both the democrat and the republicans and Enron being another symptom of the irresponsibility of the politicians.

I can hear your echoes that you were all following the laws of a corporate fascist driven government or just following orders. I can see the shadows of the dead Jews of Germany in WW II. A growing percentage of us just wants to mindlessly follow rules and are motivated for our own self-interest.

Our culture has taken something away from us. We have an enormous need to feel we are somebody within these mindless mechanical rules and these plastic faces of our friends. In each and every one us, our spirit is dragging a ton of weight. In an increasingly unstable world, we cleave for authority, security, and no risk- and we trade away our inalienable right to be a free human being. We welcome the illusionary stability of fascism and there is a profit for a small percentage of the population, and the bureaucracy.

In our democracy, in our freedoms to build and choose who we are, in that process of continually recreating ourselves; and always in the inherent the goodness of the people of this country; there is so much hope in a brighter future for the world. But there is a darkness that is approaching. It has to be acted on. Is here right now! We can not ignore it at our own peril. Please be the one who speaks for our freedoms and for the oppressed. Please change the world. Take the risk to fly above your bureaucracy!

Make waves! We will all be better for it in the end. You may really get what you want.

Here is a little civics lesson to the official of the NRC and other governmental agencies. Our constitution speaks of the inalienable dignity of being a human. It always was meant to speak to the people of the lesser, and the oppressed, and the loudest. When this country was being born, we all the oppressed. It says, our rights and responsibilities don't dwell in the government or any bureaucracy. It comes from the creator. In many ways, this means it's your first responsibility is to consider the morality of right or wrong in your heart and your intelligence. It not an allegiance to any bureaucracy, laws, or government. It is an allegiance to the common dignity of women and men, and more so for those who have less than us. It is in the highest patriotism of the universe, as in the foundation of our country, to challenge any system, bureaucracy, and governments. To make sure these governments always remained aligned to the dignity of men and women, and always more especially to our least, and especially to our least.

Not many get it; you have no idea when you will be first, or last in line, on a whim it can change. To put your brothers self interest ahead of your interest is truly in your highest interest. Every one of us here in the United States has a high responsibility to keep a small part of their head independent of government, judgmental and forever challenging of government, and the people who have governmental powers.

Following the laws are not near enough if you are a true American, for you have to follow your heart, your love, and your intelligence. You have to love your brother first and then follow the applicability of laws. And for the truly brave Americans, the land of the very few these days, you may have to put your families and your self-interest at the bottom of the list. Who said freedom is nothing left to loose.

The question at hand is comments about event reports, and what's the responsibility of a corporation having business in the Unite States: A business who has an astonishing concentration of human hazards in their control. You know what, if these corporations don't want to conform to the ideals of transparency commensurate to their potential threat to the population, they shouldn't be allowed to operate in the U.S.

"SHUT THEM DOWN". To sit there and say that the NRC can't force or persuade these corporation to timely inform the public is hogwash. As an example, a NRC spokesman could go to the media around the plant saying these are the transparency standards and expectation of our governmental agency, and this facility is not conforming to them. The public would howl so loud you would have the facility begging. You could also tell the public that you would pull away the local inspectors until the facility conforms to the transparency requirements.

This putting up a barbed wire curtain for the corporation with information, is the beginning of an ugly form

Robert Pulsifer - Additional 2.206 For Vermont YanYee P Page 12 12 fascism. It is seductive, easier on the bureaucracy, brings rewards, and ultimately creates world instability.

It's aim, is to disconnect and disrupt the peoples trust in government, for the benefit of the few. It is a fact of history that the few, who observe worldwide crisis of not their making, non-the-less, calculates their potential profits, the power enhancement, from the instability that was created. It may go on that they create additional instability.

I'm asking a lot from the NRC. That it is to become a regulatory authority of the United States Government. It is to stop acting as if the corporations ARE THE GOVERNMENT and you are the victim of their reach. It is to stop turning the public into your enemies or to tag anybody who disagrees with you as potential terrorist.

You job is not to serve profits. It is to serve what's good and right for our future. Maybe it will take a few of you bureaucrats to begin raising a little hell and put you self-interest on the backside of your list?

Evolutionary theory says self-interest made you crawl out of the oceans. Made you stand up and walk. I ask, what evolutionary benefit came from looking to the stars. 'Tis a waste of time. I say inspiration. It's why we built it. What say you? Truly evolution of comic proportions, that of which you are capable of, says you now need to put your material and personnel self-interest, put them at the back of the list. You've got sisters and brother who are in a lot of trouble e out there. You have to love your brothers and sisters as you would yourself- and maybe more so the least the least of you. Revolutionary evolution!

Maybe its time that you remember whom to serve - and where we all came from? We are all the home of the brave and the free aren't we! Will you be that lamp to the world that leads them to the golden door?

a.. Keep, ancient lands, your storied pomp!" cries she With silent lips. "Give me your tired, your poor, Your huddled masses yearning to breathe free, The wretched refuse of your teeming shore.

Send these, the homeless, tempest-tossed, to me; I lift my lamp beside the golden door."

Emma Lazarus (1849-87), U.S. poet. The New Colossus, (1886), written for inscription on the Statue of Liberty.

Sincerely, mike mulligan Hinsdale, NH 16033387179