ML19294B105
| ML19294B105 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 02/12/1980 |
| From: | Harold Denton Office of Nuclear Reactor Regulation |
| To: | Herskovitz M AFFILIATION NOT ASSIGNED |
| References | |
| NUDOCS 8002270138 | |
| Download: ML19294B105 (1) | |
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February 12, 1980
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Mr. Michael Herskovitz 9906 President Street Philadelphia, Pennsylvania 19115
Dear Mr. Herskovitz:
A copy of your letter of 1.ovember 14, 1979, to the Department of Energy was sent by the DOE to tht Nuclear Regulatory Commission on December 3.
You proposed that a special corporation be fonned under the auspices of the Congress to operate all nuclear power plants in the United States.
You may be inteepstad in the enclosed section of a report to the Commiseisners and the public on Three Mile Island by a Special Inquiry Graup of the Nuclear Regulatory Commission. This section, entitled
" Chartering of a National Operating Company or Consortium," suggests that some, but not all, nuclear plants could' be operated by an industry wide consortium or a sublic corporation. This matter is under consider-ation by the Nuclear Regulatory Commission.
We appreciate your interest in this subject and thank you for your letter.
Sincerely, A
/ Harold R. Denton, Director Office of Nuclear Reacter Regulation
Enclosure:
As stated
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3 CHARTERING OF A NATIONAL OPERATING COMPANY OR CONSORTIUM In discussions we conducted with our consultants, with senior management of a number of vendors and architect-engineer firms (AEs), and with others in the industry we repeatedly heard that there is a wide spectrum in the_ capability of the various nuclear utilities to operate existing plants in a safe fashion. The reasons for this variation appear to be twofold.
First, some utilities have more nuclear experience and a larger group of technically competent nuclear personnel than others. Although the law places sole responsibility for the safe construction and operation of a nuclear powerplant on the utility company that owns it-the NRC's " licensee"-the utility typicaily possesses less nuclear expertise than any other participant in the enterprise. Most often the real engineering talent lies primarily with the " vendors" and AEs wiio design and build the plants, and with the NRC.
Some of the first commercial nuclear plants were " turnkey" projects designed and
- built entirely by vendors-General Electric or Westinghouse-for a fixed price and then turned over to utilities for operation. In this country that pattern has changed. A utility now hires an architect engineer firm like Bechtel, Stone & Webster, F " the case of TMI-2, Burns and Roe, to serve as " general contractor," design vverall layout of the plant, and serve as the utility's technical advisor in buying a cendor's reactor system, which in price may amount nowadays to no mo.e than 15 to 20% of the total project.
But the distribution of expertise has not changed. Except in the case of the largest and most experienced nuclear utilities, it is the vendor's and AE's experts as the champions of the utility who do battle with the NRC's experts to win a license. They also construct and supervise the testing of the new plant. In the meantime, the vendor and AE are also helping the utility to build up its operating and engineering departments, to find and train competent operators and supervisors to run the yet-to-be-completed plant, and to write operating procedures. When testing is complete and the plant goes into service, the utility is on its own.
Vendors especially are resentful of the suggestion that they are like new car dealers who " flip the keys" to the car buyer and then walk off the lot. But the fact remains that any continuing partnership between the operating utility and the vendor depends in large part upon the utility's willingness to pay for additional services.
The second reason for the variation in nuclear capability among the various utilities appears to be that different utility companies accord their nuclear generation units different priorities and different amounts of resources.
109
O The electric utility industry has recently established an industrywide institute of Nuclear Fower Operations (INPO) that will undertake to police and upgrade the m?.aagement and operating competence of its members.
We believe INPO can play an especially important role in providing affirmative assistance to its members to upgrade the competence of their site crews and management-assistance the NRC cannot easily provide without compromising its enforcement role.
I If INPO is linked to a plan for coinsurance by a pool of utilities of the cost of replacement power that would have to be purchased by any one utility after a nuclear accident shut down its plant-so that a utility not receiving a passing grade from INPO's inspectors and auditors would be excluded from the coinsurance pool-this approach has some chance for success. We urge its rapid implementation. At the moment, however, it is still a promising possibility, not yet implemented.
The fact remains that nuc ear technology is d:fferent in kind from the traditional technology of electric genention by fossil fuel and hydroelectric means-more dangerous, more sophisticated and more demanding of advanced management, maintenance, and quality control. It may be that some utilities, because of their limited size, limited technical staffs or limited capital, simply will not be able to meet the increased demands we think the Three Mile island accident demonstrates must be made upon them by the NRC to provide a technically competent site management team on every shift, first class operator training programs and other safety improvements. If that is true, then some alternative must be found to provide for the safe operation of these plants.
We suggest that a number of existing piants now owned by different utilities could be operated (and new plants constructed) by an industrywide consortium or a public corporation such as COMSAT. This entity would manage the plants; select, train, and employ operators, supervisors, and engineers; standardize operating conditions and procedures; and, with the cooperation of vendors, systematically evaluate operating experience and implement changes in design or operations. Operating budgets could then be developed on a systemwide basis.
The company or consortium would either acquire the plants and sell electric power to the utilities for resale to cunomers, or it would operate existing plants now owned by the smaller utilities and provide additional technical assistance to these utilities on a contract basis. Under the latter approach the operating company or consortium would report to each utility its share of operating expenses and capital improvements at appropriate intervals for the utility to report to its State public utility commission.
The existence of a chartered national operating company or consortium could also help to resolve the regulatory dilemma in which the NRC may find itself if it determines that a particular utility has not put together a technical and management team capable of operating its plant safely. At present, the only weapons in the NRC's regulatory arsenal are rather trivial fines on the one hand, or the authority to close down a plant on the other, thus depriving the area of needed electric power and making it even more difficult for the utility licensee to rehabilitate the situation. With a national consortium or operating company in existence and licensed by the NRC, the agency could put a powerplant that is below the acceptable level of safety into " receivership," requiring 110
that its operat;cn be undertaken by the national company as a condition of the utility keeping its operating license.
This suggestion obviously calls for important institutional changes, but they are hardly revolutionary. A proposal that allnuclea' powerplants should be operated by a single, Government-chartered entity in order to standardize operations and upgrade safety has been made on more than one occasion by well-known experts in the field of nuclear power. We think that something short of this proposal-the availability of a consortium or national operating company to run some plantc can be a useful solution to the resourcer problems of smaller utilities an can be beneficial to the level of safety throughout the nuclearindustry.
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De artment of Energy Washington, D.C. 20545 December 3, 1979 Mr. Michael Her ovitz 9906 President etreet Philadelphia, A 19115
Dear Mr. E arskovitz:
Your letter of November 14, 1979 to Secretary of Energy Duncan regarding the SANE concept has been referred to this office for reply.
As explained in enclosure 1 to your letter, the SANE concept deals with an innovative way to provide personnel to administer and oparate nuclear power plants so as to provide for their safe operation. We applaud your f.nterest in optimizing the safe operation of nuclear power plants.
However, the Department of Energy is not the agency most qualified to respond directly to your request for a study of the SANE concept; within the Federal Government the responsibility for regulating the operation of nuclear power plants lies with the Nuclear Regulatory Com=ission (NRC),
Washington, D. C. 20555. Accordingly, we are trans itting a copy of your letter and enclosures to the NRC for consideration.
Your interest in nuclear power as a safe means of providing for the National welfare is appreciated.
Sincerely,
/
A. J. Pressesky, Direc r Division of Nuclear Power Development cc: Ofc of Public
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M Affairs, NRC w/cy incoming s
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Y Michael Herskovitz 9906 President Str
'4 November 1979 The Honorable Mr C. W. Duncan Jr.
Secretary Of Energy Washington, D.C 20545
Dear Mr Duncan:
In view of the recent TMI incident and the consequent findings of the presidential commission on the
- matter, I
believe you'll find the remainder of this letter worthy of your personal attention.
The purpose of this letter is to bring to your attention - as head of DOE -
a new and exciting concept in safe generation of nuclear energy.
To the best of my knowledge, the ccacept is both unirue and unprecedented.
g Since the scope e f the concept is much to large to discuss over an introeuctory
- letter, En clo sure 1 to this letter highlights some of the concept's fundamental principles.
Howeva,
I would appreciate the opportunity to discuss this matter In mor,e details with you and your staff.
Since your department probably receives many suggestions from "un knc >'n" individuals, I have enclosed a brief resume' of myself (Enclosure 2).
The purpose of the resume' is to convey to you my sincerity and my qualifications.
The resume' also indicates my personal career objectives as they relate to this matter.
I would appreciate hearing from you as soon as possible since other agencies may be interested in my concept.
Until I l.
hear from you, I remain Respectfully Yours l
Michael Herskovit3f/
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. - Fundamental principles of the SANE Concept.
The SANE accronym stands for Safe Nuclear Energy and was first conceived by Michael Herskovitz in Philadelphia.
The concept combines underlying principles of our constitution with the wellfare of the people and the need for nuclear energy in a unique and unprecedented f a s h i'o n.
In a
- nutshell, the concept proposes that a special corporation be formed - similar to a public utility
- compeny, but under the auspices of the U.S Congress - to operate (and only operate) all nuclear power plants in the U.S.
The corporation and it's employees shall not own - in part or in whole - nuclear power plants operating in the U.S.
The corporation will be formed as a business entity to supply local utilities and owners of nuclear power plants with trained operators, with security and administrative personnel, and with management staff.
This service will be mandateo by law and will be provided under negotiated contract with individual utilities.
The financial aspects of these contracts will be subject to legal guidelines established by the Congress.
The fundamental principles and advantages of the SANE concept are as follows:
Seperation of profit motives from safety-e Since safety is in the people's interest and is usually in direct conflict with the profit motives of utility companies, the concept proposes to seperate the plant operator from the influences and concerns of nuclear power plant owners.
This should provide the operator with a
working environment in which safety - and only safety - is the primary concern.
e Safety first-The' SANE operator, having no profit motives or other business interests, offers the American public a single source of specially ta ained professionals dedicated to the safe generation of nuclear energy.
Efficient generation of nuclear energy-e The SANE operator offers a source of specially trained, highly efficient administrative and management personnel.
This should provide for efficiency, cohesiveness, and uniformity in all aspects of nuclear energy generation and supply - nation wide.
The SANE corporation will be headed by a
five member board.
Four of the members
should be experts in the field of nuclear power generation and be so recognized by the U.S Senate.
The chairperson should be the head of COE.
e Accident prevention-The SANE operator will have the authority and responsibility to shut down an unsafe plant at the first signs of trouble.
Not subjected to local
- politics, and financially independent of the operational status of the particular plant, the SANE operator can initiate shut down and begin emergency procedures rapidly and efficiently.
To prevent the SANE operator from exserting unfair pressures on local utilities, each member of the board will be subject to recall.
Such recall proceedings may be initiated by a
recall letter sent to the U.S Congress and signed by no less then five governors.
As one can immediately realize, the concept has much to o ffe r in a
way of safe nuclear energy.
- However, the originator will be first to admit that many questions still remain to be answered before this concept can be presented the american people.
to It is therefore my personal desire to head a team of DOE personnel tasked with the
- detailed, in-depth study of the merits of the SANE concept.
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.- - Personal Resume' for:
Name Michael Herskovitz Address -
9906 President Str Phila.
Pa.
19115 Telephone -
(215) 677 - 6158 Birth date - 24 May 1952 Citizenship - U.S.A Pertinent
Background:
Education B.S Degree in ferospace Engineering from the Penn.
State University.
M.S Degree in Engineering Management from the Drexel University in Philadelphia.
(An engineering equivallent to an M.B.A)
Professional Career:
Four years (1974-1978) with the Boeiag Ver tol Company.
Three years as per formanc e analyst.
One year as project engineer.
At present working with the Naval Air Development Center in Warminster Pa.
Current position is project engineer on a Navy Systems concepts. addressing R&D of advanced energy efficient Naval Air program Career Objectives Desire a position as project manager of a
team of DOE specialists Thc abjectives of the team would betasked to examine the merits of the SANE to conduct an in-depth study of the concept, including a determination of the legal, t
economic, and political implications.
The primary goal would be to prepare a formal briefing to the U.S Congress.
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