Subject 2.206: Non Testable Nuclear Plant Safety Systems at VY

March 25, 2011
William Borchardt
Executive Director for Operations
US Nuclear Regulatory Commission
Washington, DC 20555-0001

Subject 2.206: Request a emergency shutdown of Vermont Yankee because the Reactor Oversight Program is ineffective and Entergy has a documented history of a culture of falsification and thumbing their noses at reoccurring violations. It should be noted in this inspection period most of the fleet of Entergy’s plants are on fire and burning in the Gulf of Mexico with numerous NRC inspection findings including Palisades, Grand Gulf, River Bend, Arkansas One and Cooper.

Dear Mr. Borchardt,

In the 1942 movie Casablanca:

Rick Blaine: How can you close me up? On what grounds?
Captain Louis Renault: I'm shocked, shocked to find that gambling is going on in here.

Jan 18, 2011: My 2.206 Emergency Shutdown of Vermont Yankee

“The safety culture of the plant is impaired because of information inaccuracies and wide spread acceptance of falsifications.”
I request Vermont Yankee to be immediately be shut down and that Entergy be prohibited from owning nuclear power plants... because Entergy doesn’t have the integrity to tell the truth about safety and nuclear power plant issues. Money and profits comes before truth telling and full disclosures.”

http://www.nytimes.com/gwire/2011/03/24/24greenwire-japan-disaster-raises-questions-about-backup-p-16451.html?scp=1&sq=backup%20power&st=cse

Vermont Yankee has many pretend and illusory nuclear safety systems. These incomplete systems are designed to the give the public a illusion of safety but in reality these systems have never been tested and the employees are completely unfamiliar with their operation. There are only partially tested and most of them are only tested by a partial simulation. A computer simulation doesn't cut it.

I submit to you a nuclear safety system is only one that has been completely tested under real conditions once and the employees on a continuing bases actually puts their hands on this system to operate it. If you are afraid to test nuclear protection safety systems because it might damage equipment and the employees are too inexperience to operate them, you are afraid they will damage equipment and delay making money, then by definition it is not a nuclear safety.

Oh baby, bring out the risk perspectives now. I eat the whole industry alive!

We know the industry has gone into many pretend and illusory non testable nuclear safety systems in a big way. How many are there?

Illusory and non testable safety systems at VY. This is a incomplete list :

1) The Automatic Depressurization System(ADS)...the main steam safety relief system.
2) The Vernon tie
3) The Service Water System and RHR system tie and the emergency cooling tower cell. This is the backup cooling system for the emergency diesel generators.
4)Alternate shutdown outside the control room. Discuss why you went to the tie instead of the SW/RHR cross connect.
5) ECCS functional every outage.

I like to talk about the VY 1992 Loop and impaired diesel generator cooling, and how I predicted it. You know the routine now:

1)Request all non testable safety system be immediately tested or the plant shutdown.
2) Request a outside the NRC investigation of this NRC behavior for tolerating this atrocious regulatory behavior.
3) Request top Vermont Yankee Management staff be fired and replaced before startup.
4) Request Entergy’s corporate nuclear senior staff be fired and replaced before the restart of the plants.
...5) Request the formation of a local public oversight panel around every nuclear plant.
...6) Request a emergency NRC senior official oversight panel with the aims of
reforming the ROP.
...7) Request a national NRC oversight panel of outsiders to overseer and report on the agency’s activities. There should be a mixture of professional academic people and capable lay people.
8) There is some heavy duty and exceedingly numerous findings of problems with Entergy plants’ this inspection reporting cycle...do an analysis of why this is occurring.
9) Request a list of non testable nuclear safety systems country wide!

Sincerely,

Mike Mulligan
Hinsdale, NH
1-603-336-8320
steamshovel2002@yahoo.com