So senior project engineer Richard Guzman was assigned my petition manager for my Pilgrim SRV 2.206. I have hit him pretty hard in the last few days and I got a few more tough documents to send him in the next few days. He certainly knows I live but a few miles from VY.
From: "Guzman, Richard"
Sent: Thursday, March 14, 2013 3:05 PM
Subject: RE: 2.206: Pilgrim Nuclear Plant SRV Request for Emergency Shutdown
Mr. Mulligan,
Your 2.206 petition by email dated March 7, 2013, was assigned to the Office of Nuclear Reactor Regulation (NRR) for review. My name is Richard Guzman, NRR project manager in the Division of Operating Reactor Licensing, and I have been assigned as the petition manager for your petition...So my VY petition manager and senior project manager Guzman are in the media this morning (March, 21, 2013) questioning the financial qualification of Vermont Yankee though an official request. He questioned VY management beginning on Feb 14.
NRC Say Entergy-Vermont Yankee Isn't Financial Qualified To Have A Licence (March 21, 3013)
"But those changes prompted the NRC to ask for what it called “updated pro formas for the operations and maintenance and cash flow for Vermont Yankee” up to 2018.Suspiciously another VY project manager pops my yahoo mail at 1 pm this afternoon. I am shocked, shocked I was rejected again...
“The NRC staff requires further information to insure that the licensee is meeting NRC requirements for financial qualifications,” said the letter, signed by Richard Guzman, senior project manager for the NRC."
From: "Kim, James"Obviously, the agency sets these messages in motion for my benefit today...to signal we understand Entergy is in trouble and we are limited in what we can do. We received and understand your message with your signals with Vermont Yankee and Pilgrim.
To: Michael Mulligan
Sent: Thursday, March 21, 2013 1:18 PM Subject: PRB's Initial Recommendation on your 2.206 petition-Vermont Yankee SRV LER
Mr. Mulligan,
On January 23, 2013, the PRB met internally to discuss your petition regarding the Vermont Yankee SRV LERs and to make an initial recommendation. The PRB determined that some of the petition requests do not meet the criteria for review because the petition failed to provide sufficient facts to warrant further inquiry
This this drive me distractingly crazy for no reason...Mr. Kim is a "project manager, DORL and Mr. Guzman is "senior project manager", "NNR/DORL/LPL1-1"...did I get a silent promotion here somewhere...
It is really painful to make me hear my uneducated speech again...
10 CFR 2.206 Petition Review Board RE Peach Bottom Units 2 and 3Feb 13, 2013
"CFR 50.73(a) (2) (v) (D), "In the event a condition that could have prevented the fulfillment of the safety functions of structures or systems that needed to mitigate the consequence of an accident." I still can't get over that. Exelon is cutting their dividend and they're cutting their capital budgets, and they're not upgrading any of their nuclear plants to the tune of $2.3 million, billion dollars, excuse me, got to get my Bs right.The President's Commission On: THE ACCIDENT AT TMI
I mean, I just -- the pressures that are going on here in all these big plants, all these big companies, biggest utilities in the United States are tremendous, and a lot of people are worrying, and I worry the NRC's asleep. Things are changing, and the -- like I said with budgets, inside a plant, you know, I mean, the first thing you realize is that how blind you are when you're going into the budget problems.
And the second thing that anybody has gotten burnt by these budget problems and cause institutional problems is you've got to ramp up your honesty 100 times and stuff like that. I mean, that's -- you've got to communicate more honestly and more completely. That's the only way -- if you have a budget crisis or lack of budgets, or limitations, priorities and stuff like that. You've got to communicate more between people and within the organizations and stuff like that. You just can't just sit there and say the easy way out is we're going to cut 5 percent and that'll be easy. You really have to do a lot of extra stuff.
You know, really it's -- what has the agency done? You know, what has the agency done to ramp up this honesty and kind of confront this? Why is-- that seems to be a lot of problems with plants now.
What is the root cause, what are the factors that cause this, what are the deeper factors that cause this and all that sort of stuff? Instead of just sticking there and, you know, looking at a threaded seal as an isolated part and not worrying and wringing your hands, and pulling out your hair wondering what's the big picture? I've got to know the big picture behind what's causing these little problems. And if you have a little problem here that's similar to another little problem here, you know, why ain't you pulling out more of your hair and stuff like that? Where's the worry? I don't see that. I see these -- I see the agency running around basically feeling comfortable that they're following the rules that the politicians wrote for them and stuff like that. I see a lot of agency people not having a conscience because they're probably going to get punished or pay a price if they look at the bigger picture, and challenge their conscience, and challenge their status and things, and try to make the agency be prepared for this falling off the cliff of most of our major utilities with natural gas.
This is a Hurricane Katrina. This is a Hurricane Sandy. This is a Blizzard Nemo that's coming down on you guys, and you can't operate like the way you've done in the past. And you should be banging on these politicians to help you out as far as rules and regulations, and to be able to see more, and to be able to use a sledgehammer to get people's attention at times, especially these executives and stuff like that.
We're really going to do damage to our nation if we don't get a handle on what's going on here. This is a climate change. This is a huge economic climate change that's going on in the industry as far as this natural gas business. We don't know how long this thing is going to last, but as it is now it's affecting so many people and stuff like that. You know, the politicians are supposed to be in there helping the agency to do the people's business.
You know, we can't have this independent agency out here disconnected from the politicians and stuff like that. We have to have the politicians helping us to manage our electric system, and especially this invaluable 20 percent component of our electric system. We really need a lot of people. You know, they're all mixed up in Washington, too busy doing this and being overwhelmed by that. They sit there and too many problems, and too many limitations, and too lack of vision. And it's -- I fear for the future if we don't wake up.
I'm Mike Mulligan, and thank you for this opportunity. I'm done."
Oct 30, 1979
"ATTITUDES AND PRACTICES (Pg 9)
In the testimony we received, one word occurred over and over again. That word is "mindset." At one of our public hearings, Roger Mattson, director of NRC's Division of Systems Safety, used that word five times within a span of 10 minutes. For example: "I think [ the] mindset [was] that the operator was a force for good, that if you discounted him, it was a measure of conservatism." In other words, they concentrated on equipment, assuming that the presence of operators could only improve the situation -- they would not be part of the problem.
We note a preoccupation with regulations. It is, of course, the responsibility of the Nuclear Regulatory Commission to issue regulations to assure the safety of nuclear power plants. However, we are convinced that regulations alone cannot assure safety. Indeed, once regulations become as voluminous and complex as those regulations now in place, they can serve as a negative factor in nuclear safety. The regulations are so complex that immense efforts are required by the utility, by its suppliers, and by the NRC to assure that regulations are complied with. The satisfaction of regulatory requirements is equated with safety.This Commission believes that it is an absorbing concern with safety that will bring about safety -- not just the meeting of narrow prescribed and complex regulations."
http://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber='ML13052A379'
10 CFR 2.206 Petition Review Board RE Peach Bottom Units 2 and 3
http://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber='ML13016A278'
10 CFR 2.206 PETITION RE: VERMONT NUCLEAR POWER PLANT
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