ML052310163

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Ltr Dated 08/14/05, Perry Performance Improvement Initiative
ML052310163
Person / Time
Site: Perry FirstEnergy icon.png
Issue date: 08/14/2005
From: Tom Gurdziel
- No Known Affiliation
To: Caldwell J
Region 3 Administrator
References
IR-05-003
Download: ML052310163 (2)


Text

9 Twin Orchard Drive Oswego, NY 13 126 August 14,2005 James L. Caldwell Regional Administrator USNRC Region 111 2443 Warrenville Road, Suite 210 Lisle, E 60532-4352

Dear Mr. James L. Caldwell:

I have read a letter dated August 8,2005 providing the FENOC response to IR 05000440/2005003. I have some comments.

I guess the first comment would have to be that the Perry Performance Improvement Initiative was not hlly a success if it needs a (previously unannounced) Phase 2.

My next comment is a prediction that Phase 2 will not be successfi~l(and that a Phase 3 will be offered). I feel Phase 2 is aimed at the wrong root cause. They seem to think that their programs are in need of improvement. Actually, I dont think their programs matter much. Their need is for workers with technical knowledge and judgment that are both empowered to work properly in their assigned functional area and held accountable if they dont.

Presently, I dont see this happening. In fact, how could anybody conclude Perry workers are being held accountable if they can make the same mistake about 100 times in 6 years just installing fasteners?

Here is what I think needs to be done. First, get somebody that can run a BWR to specify the jobs that need to be done and the necessary skill levels of the people assigned to each job. (Perhaps EntergyFitzPatrick would be a choice based on their recent handling of a primary containment breach). Next, check each site assigned person against the specified job requirements.

Note that this can be done at zero percent power. And, it could be done under a 0350 committee. In fact, I request that it be done at zero power under a 0350 committee.

This is Letter 3. I need no reply.

Copy: D. Lochbaum GUG 1 9 2001

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