ML083530209
| ML083530209 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 11/13/2008 |
| From: | Mulligan M - No Known Affiliation |
| To: | James Kim Division of Operating Reactor Licensing |
| Kim J, NRR/DORL, 415-4125 | |
| References | |
| 2.206, TAC MD9843 | |
| Download: ML083530209 (5) | |
Text
From:
Michael Mulligan [steamshovel2002@yahoo.com]
Sent:
Thursday, November 13, 2008 11:17 PM To:
Subject:
Re: 10 CFR 2.206 Petition dated 9/28/08 on the Vermont Yankee EDG
- James, I discovered this as I was writing out my bullets for the 2.206. I am taking my best shot at explaining what I see as a outsider, with the possible worst case. I consider this a safety concern I am sending you and it's related to the 2.206. I'll cover it in the board meeting.
If it is not explainable...then VY should be in a LCO? Sorry about the extra work.
- Thanks, Mike Mulligan Hinsdale, NH
...The 1991 DG overload LER (LER #: 90-010-02) says..."The Overload Rating - 3000 kW for 7 days, not to exceed 3025 kW for more than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in any 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period".
...The NRC states in their engineering inspection (05000271/2008008) on Sept 2008 "The UFSAR further stated that the generators can be manually loaded up to 3000 kW for 7days, and to the short time rating of hours at 3025 kW 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in any 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period (at the discretion of the operators)."
You see how the greater than 2750kw in the 1991 LER was an "The Overload Rating" while in 2008 it was changed to a "it can be manually loaded rating"....read that Overload, Overload, Overload. Don't forget they capitalized the first letters trying to gain your attention it was going passed the machine design..."The Overload Rating" So the licensing needed load is around 2900 kW..while the the normal continuous load limit is 2750kW...anything over 2750 kw is an overload per 1991....
The Sept/08 inspection adds this "(at the discretion of the operators)". When and why did they add this, it's not in the 1991 LER. This is cuing the operator's that you are risking your career even if you follow the procedures...this baby might blow because we gamed the procedures and FSAR!
You see how much trouble they are in? Have you ever read George Orwell's 1984 yet? I mean, it's bad that the NRC didn't catch it or explain it in the past. They are selling you a bill of goods, you purchased it, and it's at a lower quality than advertised and the guaranty you got when you purchased.
They tell me for the manufacturers and service contractors of the machine, say for
$10,000 or more, maybe a lucrative service contract....they will guaranty under oath to the NRC that if the diesel generator are thrown into the Connecticut river, these units will float on the river for a week before sinking to bottom.
What happens if the manufacturer comes under a credibility cloud... all the nukes use the same manufacturer?
I would say...right now they have to call both diesel generators inop, they are operating that plant illegally...they must be shutdown because they can't meet their design emergency power electrical loads.It's a common mode failure. As it sits here, that plant is operating illegally, the tech specs requires them to be shutdown.
They have writing their FSARS' and procedures' on a chalk board...anyone can come into the room and erase any phrase in the documents and replace it with a more pleasing phrase.
- Thanks, Mike Mulligan Hinsdale,NH From: Michael Mulligan <steamshovel2002@yahoo.com>
To: James Kim <James.Kim@nrc.gov>
Sent: Thursday, November 13, 2008 10:21:15 AM
Subject:
Re: 10 CFR 2.206 Petition dated 9/28/08 on the Vermont Yankee EDG
- James, That date would be fine...is it OK with VY? I'll send you some bullets on my issues later today. I say 1:20 hours should be way enough... for my explanation, it should be very short and sweet, but if you guys (NRC/ VY) get talky, it might go all the way.
I am a transparency fanatic...I have no need of any confidentiality on anything...hope VY is there and anyone else who wants listen in.
Just in case, would you e-mail me a few days warning prior to Noc 24th...just to make sure I don't waste any ones time and effort.
You can ask me any question and clarifications at any time, which may help the situation out prior to the 24th. I been through a few 2.206's a few times before...never successful though.
- Thanks, Mike Mulligan Hinsdlae, NH From: James Kim <James.Kim@nrc.gov>
To: "steamshovel2002@yahoo.com" <steamshovel2002@yahoo.com>
Sent: Wednesday, November 12, 2008 3:36:19 PM
Subject:
FW: 10 CFR 2.206 Petition dated 9/28/08 on the Vermont Yankee EDG Mr. Mulligan, It appears that the petition review board (PRB) chairman is available on Monday, November 24th (10 -11 a.m.) to hold a teleconference for you to address the PRB to provide any additional information. Please let me know whether 11/24/08 at 10:00 am is acceptable for you to hold a teleconference. How much time do you think you need during the teleconference to provide the additional information (10-20 minutes)?
Thanks James Kim Vermont Yankee Project Manager, DORL U.S. Nuclear Regulatory Commission 301-415-4125 E-mail: james.kim@nrc.gov From: James Kim Sent: Friday, October 10, 2008 1:19 PM To: 'steamshovel2002@yahoo.com'
Subject:
10 CFR 2.206 Petition dated 9/28/08 on the Vermont Yankee EDG Mr. Mulligan, Your E-mail petition dated September 28, 2008, was assigned to the Office of Nuclear Reactor Regulation (NRR) for review. My name is James Kim, the NRR project manager for the Vermont Yankee nuclear plant and I have been assigned as a petition manager.
The 10 CFR 2.206 process is a public process, in which your petition and the NRC documentation related to your petition will be made public, including your identity. If you do not wish your petition to be made public, please advise us of that immediately and we can suggest other NRC processes to you, such as our allegation process.
The NRC will convene a Petition Review Board (PRB) to discuss your 2.206 petition request.
During its meeting, the PRB will discuss the request for immediate action. After that meeting, you will be informed on the PRB's preliminary recommendations.
In accordance with the 10 CFR 2.206 process, the PRB is offering you an opportunity to address the PRB, in person or by teleconference, to provide any additional information you may wish to provide. Please let me know if you wish to address the PRB, and when would be good for you (during normal working hours).
James Kim Vermont Yankee Project Manager, DORL U.S. Nuclear Regulatory Commission 301-415-4125 E-mail: james.kim@nrc.gov E-mail Properties Mail Envelope Properties (953841.8031.qm)
Subject:
Re: 10 CFR 2.206 Petition dated 9/28/08 on the Vermont Yankee EDG Sent Date: 11/13/2008 11:17:12 PM Received Date: 11/13/2008 11:17:12 PM From: Michael Mulligan Created By: steamshovel2002@yahoo.com Recipients:
James.Kim@nrc.gov (James Kim)
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