ML030690656
| ML030690656 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 12/07/2002 |
| From: | Tom Gurdziel - No Known Affiliation |
| To: | Grobe J Division of Reactor Safety III |
| References | |
| Download: ML030690656 (2) | |
Text
9 Twin Orchard Drive Oswego, NY 13126 December 7, 2002 Mr. John A. Grobe, Director Division of Reactor Safety US Nuclear Regulatory Commission 801 Warrenville Road Lisle, IL 60532-4351
Dear Mr. John A. Grobe:
I have just read a Regulatory Commitment Change Summary Report for Davis-Besse. It is ML023260058 in ADAMS. I have comments on a number of them.
Commitment 008625 required that a list of qualified design reviewers be maintained.
Since it is "not administratively necessary," it is not to be done anymore. I think it is necessary.
Commitment 012223 appears to state that avoiding a radiation dose is more important than doing a proper job. Additionally it uses the production oriented philosophy that the plant must always be kept running: actually, the failed transmitter could be fixed when not "at power" if the plant would be shut down for the repair. Or, perhaps a redundant pressure transmitter could also be installed. Otherwise it seems they are using an operator work-around, which I thought they said they would not do.
Commitment 015277 confuses changing diesel engine oil with sampling the oil.
Replacing the oil every 12 months will not provide early warning of problems, but sampling might. (This shows a lack of understanding of predictive maintenance.)
Commitment 015555 (for both Decay Heat Cooler and CCW Heat Exchanger) ignores the possibility that performance may deteriorate with age. This is a production oriented change.
Commitment 015921 appears to be a throwback to maintenance before the 1980s, if I understand it correctly.
Commitment 017419 seems to confuse valve exercising with IST valve testing. Also, couldn't testing it in the (ten year long) second interval be easily deferred to the next interval, and then the next?
Commitment 005641 shows that low radiation dose is more important than doing the job properly. This is production oriented.
Since the cover letter was dated November 18, 2002, I had expected to see less production oriented reasons.
This is my sixteenth letter. It needs no reply.
Thank ou, Tom. A.rdVie.l Copy: D. Lochbaum