NRC Acknowledgment of Palisades 2.206

Me

To Chairman@nrc.gov

Mar 11

Dear Chairperson McFarland,

If you really believed this from your recent speech…

“As we continue to strive for effective, credible regulation, and assist other regulators in upholding these values, our commitment to continuous learning is critical. I believe that when we demonstrate that our decisions reflect the best available information, and when we demonstrate openness to external interlocutors, it enhances public confidence. This is an objective I’ve embraced since my tenure at NRC began, and I continue to believe in its importance. 

 

…you’d help me gain much better transparency in my upcoming Palisades 2.206. The 2.206 processes for an outsider are a travesty and circus. It is designed for an outsider to fail most of the time because of a lack of evidence. It should be a firing or disciplinary offence if a NRC employee ever misleads a petitioner or to withheld information from inside this process. You’d make a licensee answerable to my questions or severe consequences.
 

How about all petitioners’ activities and the whole process be recorded and put on your NRC internet site?

There is a tremendous difference in power between me and the NRC/licensee...while you guys have almost unlimited god like powers to withhold information based on unseen justifications. I remain utterly powerless and have no rights of transparency within this process. But I do have the right to get my letter in the NRC documents, and of course, I get a shot for you to transcribe my words by a telephone bridge to many NRC employees. I have to admit there is substantial power in this for a petitioner.
 

If you really believed what you wrote, you would help me overhaul the NRC’s 2.206 process. You would think this current system is a tremendous injustice to a petitioner, the community and mostly to the USA.

The agency should also provide me with a senior experience NRC executive...where his job is to serve a petitioner. Her job is to help me with this NRC process...explain to me in a high level position way what is going on with my issue and figure out how to get the information I need ...she is to be tasked with being my inside the NRC advocator. She would be like my special NRC lawyer...

I honestly think this would make the industry more stronger and resilient...

Sincerely,

Mike Mulligan

Hinsdale, NH

Steamshovel2002@yahoo.com

They offer me no evidence or proof it safe...all you got is officials looking a paperwork and they saying its is safe. How much experience to they have with this...how many impeller pieces have been stuck between the skirt and vessel.

 Palisades 2.206 Petition - OEDO-14-00145 - MF3608

Mr. Mulligan, I have been assigned as the Petition Manager for the 10 Code of Federal Regulations (CFR) 2.206 petition, you submitted to the Nuclear Regulatory Commission (NRC) on March 5, 2014, regar

To Me

Today at 1:33 PM

Mr. Mulligan,

I have been assigned as the Petition Manager for the 10 Code of Federal Regulations (CFR) 2.206 petition, you submitted to the Nuclear Regulatory Commission (NRC) on March 5, 2014, regarding your concerns about various issues related to equipment failures and operations at Palisades Nuclear Plant (Palisades). You also expressed concerns with NRC inspection activities and the NRC’s reactor oversight process.

Section 2.206 of Title 10 of the Code of Federal Regulations describes the petition process – the primary mechanism for the public to request enforcement action by the NRC in a public process. This process permits anyone to petition NRC to take enforcement-type action related to NRC licensees or licensed activities. Depending on the results of its evaluation, NRC could modify, suspend or revoke an NRC-issued license or take any other appropriate enforcement action to resolve a problem. The NRC staff’s guidance for the disposition of 2.206 petition requests can be found in NRC Management Directive 8.11, which is publicly available.

Because you specifically requested in your letter that the NRC take different enforcement actions as described in your petition, including your request for immediate actions to prevent the Palisades plant from restarting (i.e., Items #6 and #10 in your letter), your request was referred to the 2.206 process. The 2.206 process is separate from the allegations process; the latter which affords individuals who raise safety concerns a degree of protection of their identity. In the 2.206 process, all of the information in your letter will be made public, including your identity.

On March 14, 2014, your request for immediate action to prevent Palisades restart was reviewed by the members of the Petition Review Board (PRB), which includes staff from the NRC’s Office of Nuclear Reactor Regulation (NRR), staff from Region III, and the NRC resident inspectors at Palisades. After thorough review and discussions, the PRB reached a general consensus that there were no safety significant concerns to prevent the plant from restarting as scheduled.

The NRC has reviewed the licensee’s evaluation of the impeller piece fragment within the reactor vessel and concluded that it does not pose a threat to the reactor and other plant components. Additionally, the licensee replaced all of the 45 Control Rod Drive Mechanism (CRDM) housings prior to plant startup. Please see NRC ADAMS document ML14073A612.

Based on the review of the licensee’s evaluation related to the stuck impeller piece and replacement of all CRDM housings during the refueling outage, there were no safety significant concerns to prevent the plant from restarting as scheduled. Your request for the immediate action of shutdown of Palisades and other Entergy Plants did not have the adequate bases.

In accordance with NRC Management Directive 8.11 (which I have attached for your reference), you have the opportunity to address the NRC PRB to further discuss your petition, either in person at the NRC Headquarters in Rockville, Maryland, or by telephone conference.

Please advise me by March 25, 2014, and confirm your agreement with NRC’s processing of your request under the 2.206 process. In addition, please advise me if you would like to address the PRB. If you would like to meet in person, I will need to schedule a formal public meeting at the NRC Headquarters. If you would prefer to address the PRB via telephone, I will also work with you to coordinate a date/time during the upcoming weeks.

If I do not hear from you by March 25, 2014, the PRB will meet internally to make an initial recommendation, after which we will offer you a second opportunity to address the PRB prior to our issuing a letter accepting or rejecting the petition.

Thank you,

Mahesh (Mac) Chawla

Petition Manager

U.S. Nuclear Regulatory Commission

NRR/DORL/LPL3-1

Phone: 301-415-8371