ML082910698
| ML082910698 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 09/26/2008 |
| From: | Tom Gurdziel - No Known Affiliation |
| To: | Klein D NRC/Chairman |
| References | |
| G20080701, LTR-08-0537, SECY-2008-0593 | |
| Download: ML082910698 (5) | |
Text
EDO Principal Correspondence Control FROM:
DUE: 11/05/08 EDO CONTROL: G20080701 DOC DT: 09/26/08 FINAL REPLY:
- Oswego, New York TO:
Chairman Klein FOR SIGNATURE OF :
GRN CRC NO: 08-0537
- Leeds, NRR DESC:
ROUTING:
Indian Point (EDATS: SECY-2008-0593)
Borchardt Virgilio Mallett Ash Ordaz Cyr/Burns Collins, RI
- Schaaf, OEDO DATE: 10/17/08 ASSIGNED TO:
NRR CONTACT:
Leeds SPECIAL INSTRUCTIONS OR REMARKS:
EDATS Number: SECY-2008-0593 Source: SECY Genera Ifrato Assigned To: NRR Other Assignees:
Subject:
Indian Point
==
Description:==
OEDO Due Date: 11/5/2008 5:00 PM SECY Due Date: NONE CC Routing: Region I.
ADAMS Accession Numbers - Incoming: NONE Response/Package: NONE Ote Ifra to Cross Reference Number: G20080701, LTR-08-0537 Related Task:
File Routing: EDATS Staff Initiated: NO Recurring Item: NO Agency Lesson Learned: NO Roadmap Item: NO Action Type: Letter Priority: Medium Sensitivity: None Signature Level: NRR Urgency: NO OEDO Concurrence: NO OCM Concurrence: NO OCA Concurrence: NO Special Instructions:
Originator Name: Tom Gurdziel Date of Incoming: 9/26/2008 Originating Organization: Citizens Document Received by SECY Date: 10/16/2008 Addressee: Chairman Klein Date Response Requested by Originator: NONE Incoming Task Received: Letter Page 1 of I
OFFICE OF THE SECRETARY CORRESPONDENCE CONTROL TICKET Date Printed: Oct 15, 2008 16:00 PAPER NUMBER:
ACTION OFFICE:
LTR-08-0537 EDO LOGGING DATE: 10/15/2008 AUTHOR:
AFFILIATION:
ADDRESSEE:
SUBJECT:
Tom Gurdziel NY Dale Klein Indianf Point ACTION:
DISTRIBUTION:
LETTER DATE:
ACKNOWLEDGED SPECIAL HANDLING:
Appropriate Chairman,. Comrs 09/26/2008 No Made publicly available in ADAMS via EDO/DPC NOTES:
FILE LOCATION:
ADAMS DATE DUE:
DATE SIGNED:
EDO -- G20080701'
9 Twin Orchard Drive Oswego, NY 13126 September 26, 2008 Chairman Dale E. Klein US Nuclear Regulatory Commission Washington, DC 20555-0001
Dear Chairman Dale E. Klein:
Now that it appears Entergy's Mike Balduzzi has the back-up power emergency sirens and the Unit I fuel pool under control at Indian Point, let me point out problems in other places.
Decision Making I guess the biggest problem I see is the length of time it takes to make decisions. Maybe I should modify this statement to include: "and report them to the public". Now that we no longer use those manual typewriters, why should it take 60 days to issue an LER? Or, why is it necessary to wait 45 calendar days after a Special Inspection Exit meeting. (The 5 month goal for allegations fits right in here, too.)
Well, I think I know the reason. The NRC's (& industry's) decision making philosophy is not efficient. Presently, I believe it is something like this: "we can't make a mistake".
Now that may work when you are doing tasks you have done many times before. (Here the rule might be: "Do it right the first time.")
However, I do not believe it is practical (and certainly not timely) to demand initial perfection when doing something new. In these cases, I believe it is more efficient to make a decision with the understanding that it may turn out to be at least partially wrong.
This requires an open mind (or questioning attitude) to accept possible deficiencies in the solution and requires additional action to correct these deficiencies as they become apparent.
In fact, I believe adoption of this type of thinking is especially necessary now when you are reviewing work that has not been done before. I believe you need to accept the possibility that something can be missed and, when identified, would need to get the action necessary to fix it.
Taking Regulatory Enforcement Action Your enforcement actions are not timely and not commensurate with performance failures. For one example, a firewatch was not performed at SONGS for over 5 years.
Instead of you providing a stiff fine to a plant operator which had increased risk of operation, you allowed them to participate in Alternate Dispute Resolution. Why should a rule violator be allowed to do your job of setting the punishment?
Tunnel Vision Presently, at least for the Vermont Yankee site, the NRC is exhibiting, to me, a very severe form of tunnel vision. By looking almost exclusively at safety-related equipmegf, your actions show that all is well. But, in my opinion, it is not.
Taking just the Vermont Yankee mechanical draft cooling towers, I think the recent history goes something like this:
The plant operator determines that, if the State of Vermont would allow them to discharge into the river slightly hotter water in the summer, they wouldn't need the non-safety related mechanical draft cooling towers. So they applied for permission to discharge hotter water and got approval, but not enough to eliminate the cooling towers, It appears to me that they apparently stopped doing necessary cooling tower inspection and maintenance sometime ago. Unfortunately, the missed inspections/repairs were necessary and their absence led to a disastrous and well pictured failure in 2007. Well, they got that repaired but in 2008 another (smaller) leak appeared. Using publicly available information sources, one reason for this first 2008 failure was the failure to install the 2007-designed fix of 3 parts. (Only two were installed.)
Clearly, this high visibility repair effort did NOT follow what should have been an approved work process. Simply put, this is unsafe. There is no other way to describe nuclear-site workers not following procedures.
In fact, couldn't you say that Tunnel Vision was a large part of why the Davis-Besse head eroded so much before action was taken? And, wasn't the NRC supposed to look at all things, not just those specifically identified, according to how I remember one of the NRC's Davis-Besse Lessons Learned?
Thanky Tom Gurdziel Copy:
Commissioner Kristine L. Svinicki Commissioner Gregory B. Jaczko Commissioner Peter B. Lyons