ML043380071
| ML043380071 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 11/21/2004 |
| From: | Tom Gurdziel - No Known Affiliation |
| To: | Diaz N NRC/Chairman |
| References | |
| G20040815, LTR-04-0724 IR-04-004 | |
| Download: ML043380071 (4) | |
Text
EDO Principal Correspondence Control FROM:
DUE:
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EDO CONTROL: G20040815 DOC DT: 11/21/04 FINAL REPLY:
Tom Gurdziel TO:
Chairman Diaz FOR SIGNATURE OF :
- GRN CRC NO: 04-0724 DESC:
ROUTING:
Perry Inspection Report Reyes Virgilio Kane Merschoff Norry Dean Burns/Cyr Dyer, NRR DATE: 12/02/04 ASSIGNED TO:
CONTACT:
RIII Caldwell SPECIAL INSTRUCTIONS OR REMARKS:
For Appropriate Action.
OFFICE OF THE SECRETARY CORRESPONDENCE CONTROL TICKET Date Printed: Dec 02, 2004 09:42 PAPER NUMBER:
ACTION OFFICE:
LTR-04-0724 EDO LOGGING DATE: 11/30/2004 AUTHOR:
AFFILIATION:
ADDRESSEE:
SUBJECT:
Tom Gurdziel NY Nils Diaz Perry inspection report
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ACKNOWLEDGED SPECIAL HANDLING:
Appropriate Chairman, Comrs, OPA 11/21/2004 No Made publicly available in ADAMS via SECY/EDOIDPC NOTES:
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ADAMS DATE DUE:
DATE SIGNED:
I EDO -- C(20040815
Tom Gurdziel From:
Tom Gurdziel [tgurdzie~dreamscape.com]
Sent:
Sunday, November21, 2004 10:01 PM To:
opa3@nrc.gov Cc:
Rep. Marcy Kaptur, James M. Trapp; J. Mangels; J. Funk; David Lochbaum; Ed Stronski; opacnrc.gov; opalnrc.gov
Subject:
Perry Inspection Report 05000440/2004004 Good morning Jan, Well, this is just too much.
I am reading on page 7 that "The report also noted that the type of radworker performance deficiencies identified in the investigation were not atypical for plants in outages, and it is the frequency of occurrence that determines program effectiveness."
(They must use creative writers to produce this excuse of a total breakdown in the Perry site Radiation Protection program.)
Let my say first off that I don't remember any such complete (or even partial), breakdown at the Nine Mile Point Unit I plant in refuel outages or, even more significantly, when they did major repair work such as replace all external recirculation system piping.
(I was one of the drywell coordinators during this work at Unit I.)
Also, we would clip our self reading dosimeters on a cloth strap already sewn to the OUTSIDE of our outer protective clothing (sometimes you had to wear two pair), and stick a piece of masking tape over it to help keep from losing it.
In those days we would also wear a film badge and a thermoluminesent dosimeter.
So how were we different (in the early 1980s) from Perry in 2003? Well, we used redundant individual dose measuring instrumentation.
Perry didn't. We wore the self reader where we could get it to read.
Perry didn't. We didn't rely solely on new, unfamiliar dosimetry.
Here, Perry did.
We had Rad Protection survey areas before work began. Apparently, Perry did not.
I think we also had necessary shielding (like lead blankets, lead blocks, or water filled cubes) installed before work began.
Here again is another Perry short coming.
In particularly "hot" (radiation) areas, we would have a Radiation Protection person located at a table controlling access, which means, you didn't enter if they were not satisfied in the way you were dressed.
At Perry, workers were monitored "by exception" (page 5).
In other words, it seems to me that-Perry -upper-management would not spend resources-to do the minimum required.
This is what I call production or profit oriented, certainly not safety oriented.
(Here I am talking of the safety of their plant workers.)
And, don't you think it is interesting logic (for want of a better descriptor), to suggest that "it is the frequency of occurrence that determines program effectiveness."
page 8 "The report also recognized the effect that water chemistry control had on dose rates and that there are unknowns in this area that need to be recognized."
What are the unknowns?
Back about the end of the 1980s, I believe that Nine Mile Unit 2 tried hydrogen injection into their reactor water.
(Its use in Boiling Water Reactors was an attempt to reduce the occurrence of Intergranular Stress Corrosion Cracking, I think.)
Anyway, dose rates went up right away, if I recall correctly.
(I don't know if zinc injection causes the same effect.)
1
What I am saying here is that if Perry was injecting either hydrogen or zinc, they should have informed themselves of others' experiences over the past 15 or 20 years.
Thank you, Tom Gurdziel 2