ML030690657
| ML030690657 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 12/16/2002 |
| From: | Tom Gurdziel - No Known Affiliation |
| To: | Grobe J Division of Reactor Safety III |
| References | |
| IR-02-017 | |
| Download: ML030690657 (2) | |
Text
- 1 j7 9 Twin Orchard Drive Oswego, NY 13126 December 16, 2002 Mr. John A. Grobe, Director Division of Reactor Safety US Nuclear Regulatory Commission 801 Warrenville Road Lisle, E1 60532-4351
Dear Mr. John A. Grobe:
Management Related I was favorably impressed to read in the latest Davis-Besse inspection report (50-346/02
- 17) that an NRC person in the containment area would not accept a failure to follow rules, and instructed the worker to obtain (and wear?) safety glasses with side shields.
Then, as time passed, a few related thoughts came to mind. Here they are:
The worker did not even have safety glasses.
At the time, the plant had been in an outage for about 10 months and I assume the worker had been on site for that time, too.
The worker's supervisor did not send the worker back to get safety glasses.
At a plant I worked at during an extended outage (longer than this one), we had Radiation Protection people at important areas to check that we dressed out correctly according to the Radiation Work Permit we used. For instance, if they did not like the way we taped our gloves to our coveralls, we added more tape, or removed the tape and tried again. In other words, there was control of radiation protection requirements. Assuming Davis Besse also uses Radiation Protection people who try to do their job, this one's instructions were ignored.
I did not see in the inspection report that time off or at least a disciplinary letter was issued to the worker and the worker's supervisor. I did not see mentioned that the need to follow radiation protection instructions was reiterated to site employees.
In other words, even after 10 months of a high visibility outage, plant workers don't know what the requirements are, or decline to follow them. There is apparently no cost to them for this performance.
Also, I did not see that a Fitness for Duty for-cause drug test was required. Wouldn't you think it appropriate?
24
In my opinion, if nobody in NEI, nobody in INPO, and nobody in US NRC Inspector General's Office can identify insolent behavior, then it is not going to get changed. If high level FENOC management feels this conduct is acceptable and doesn't require change, I would say that I think they are missing the point: in this case it doesn't matter what high level management thinks is bad behavior, it matters what low level workers think is bad behavior. Anyway, it's my opinion that this is bad behavior that needs correcting.
Equipment Related There are two things that I want to mention. The first is the way it appears FENOC does hydro tests; the second is industry acceptance standards for rolling tubes.
Hydro "testing" I took off a half a day of work (11-26) to telephone in and listen to the US NRC Headquarters meeting about the lower head penetrations. It is absolutely unbelievable to me that no one present at the meeting challenged the intention to NOT look for leaks while the reactor is pressurized. It makes me wonder if this is a FENOC wide practice, a US NRC Region 3 PWR practice, or an INPO country-wide practice.
And don't you think that the concept of risk is turned around when risk to a few workers is more important than risk to a larger number of people in Ohio?
Rolling tubes How could you roll (and weld) tubes with air behind them, meet applicable acceptance standards, and not have even one question from any credible review organization about the value of what you are doing? I don't just mean the Davis-Besse site QA organization or their corporate review organization(s), I mean INPO, NEI, and US NRC Inspector General, too.
US NRC related If General Design Criteria 32 does not apply to the Davis-Besse reactor vessel, just how many reactors does it apply to? Would General Design Criteria 32 apply to the modification to the incore tubes of the Davis-Besse reactor?
This is my seventeenth letter. It needs no reply.
Thank yo Tom Gurdziel Copy: D. Lochbaum