ML101450184
| ML101450184 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 05/20/2010 |
| From: | Dan Collins - No Known Affiliation |
| To: | Donald J, Sanders C Plant Licensing Branch 1 |
| Sandeers, Carleen, NRR/DORL, 415-1603 | |
| Shared Package | |
| ML101390153 | List: |
| References | |
| FOIA/PA-2011-0115 | |
| Download: ML101450184 (3) | |
Text
From:
david collins [colldm@gmail.com]
Sent:
Thursday, May 20, 2010 9:23 AM To:
Sanders, Carleen; Jackson, Donald
Subject:
Fwd: Teleconference Meeting Thursday 20th 1:00PM Broken Barriers and Accidents Lobbyists and Government Regulations Carleen Please inform the PRB that I am cancelling this meeting [due to lack of interest at CT government level].
I would also like to remove my petition.
I would also like to withdrawi my allegations paper [I spoke with Tom Setzer and Justin Hindley about this] I will continue to work with NRC through the "rulemaking" process to improve oversight and create objective tools to identify the point at which managerial-organizational issues [like low staffing and a weak safety culture] can be said to represent unsafe operations and need to be addressed.
The (Kemeny) investigation of the accident at TMI reported:
The one theme that runs through the conclusions we have reached is that the principal deficiencies in commercial reactor safety today are not hardware problems, they are management problems The Kemeny discussions on management problems were kind of vague. The Rogovin Report on the TMI accident focused more specifically on the management issue:
Metropolitan Edison must bear the responsibility for failing to put in place a site management organization technically competent to respond to the accident. But everything we have learned in this investigation suggests that the problems in this area revealed by Three Mile Island -- inadequate training, unreasonably scanty manning levels, lack of any requirements for minimum on-site technical supervisory competence --
are common to many, probably most nuclear plants.
Right now NRC has no regulatory tools to evaluate "unreasonably scanty manning levels" NRC does not require safety culture to be addressed as part of appendix B criterian 16 "corrective actions" but a healthy safety culture is the "managerial organizational factor" that makes sure safety issues are identified and resolved. It doesn't matter how well the CAP may be functioning if the issues don't get put into the CAP in the first place.
lack of any requirements for minimum on-site technical supervisory competence all nuclear managers who manage in SRFMs [safety related functional areas] should be "safety culture qualified" [see attached glossary QPM] and there should be culture assessments that evaluate if managers are demonstrating the professional behaviors needed to keep the culture healthy [and if not managers should lose their QPM qualification, be coached and retrained, and have to demonstrate proper behaviors and pass the next cuture assessment].
Again Please inform the PRB that I am cancelling this meeting [due to lack of interest at CT government level].
Thank you, Dave Collins Greetings The current inability of government regulators to address what is the leading cause of accidents
[management issues] is at root a money issue. Companies that want to make more and more money and have the resouces to hire lobbyists that work to block or weaken needed regulations, regulators who have very good intentions but very limited resources to work with.
I am sending this invitation to people at NRC [including commissioners], members of CT government, local and national media; and a handful of authors, academics and culture experts.
I invite anyone interested in this topic to call into the 1:00 Thursday meeting and:
- 1. listen to a half hour presentation on broken managerial organizational barriers that lead to accidents and the regulations intended to assress them
- 2. join in the discussion While I have asked NRC to paln 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for this meeting, it may run less than an hour depending on the level of interest [and amount of discussion].
Here is an email from NRC containing the telecon number and code:
Mr. Collins - I have set up the teleconference for Thursday May 20, 2010, at 1:00 p.m.
The call in number is 1-800-772-3842, and the pass code is 2206. There will be 30 minutes for you to address the petition review board, as you requested.
I wanted to clarify that the petition review board has only determined that there is no immediate safety concern and therefore no immediate action will be taken. The teleconference on Thursday is an opportunity for you to address the board with regards to why action should be taken against Millstone (specifically Millstone 3, as requested in your paper). Based on the information provided in the most recent revision of your paper (the 57 page revision), the petition review boards current understanding is that you believe there are staffing safety issues, as a result of the recent staff reduction, that warrant action being taken against Millstone.
The petition review board will not make a decision on whether action should be taken against Millstone based on your request, until after you have had an opportunity to address the board. If you have any question, feel free to contact me.
Carleen Sanders Millstone Project Manager 301-415-1603 My presentation will outline the managerial organizational issues leading to TMI, Chernobyl, various events at Connecticut nuclear plants, and Davis Besse. It will discuss how similar MO deficiency broken barriers led to the BP Deepwater Horizon event, and will conclude by looking at the design of the latest NRC inspection processes that are designed to identify and resolve these kind of issues [NRC Inspection Manual Chapter 0305, NRC Inpection Procedure 95003].
I will email you documents later today or tomorrow before the meeting so you can follow the presentation clearly and easily.
I hope to hear your voice at the meeting and in the discussion.
If you do plan to addend, please notify me reply email.
Dave Collins Dave Collins E-mail Properties Mail Envelope Properties (AANLkTildrf8_meDPkP9Dm50gVynPb28rxYQEwmINy6WZ)
Subject:
Fwd: Teleconference Meeting Thursday 20th 1:00PM Broken Barriers and Accidents Lobbyists and Government Regulations Sent Date: 5/20/2010 9:23:15 AM Received Date: 5/20/2010 9:23:15 AM From: david collins Created By: colldm@gmail.com Recipients:
Carleen.Sanders@nrc.gov (Sanders, Carleen)
Tracking Status: None Donald.Jackson@nrc.gov (Jackson, Donald)
Tracking Status: None Post Office:
mail.gmail.com
Files Size Date & Time MESSAGE 21963 5/20/2010 Options Expiration Date:
Priority: olImportanceNormal ReplyRequested: False Return Notification: False Sensitivity: olNormal Recipients received: