ML20042E050
| ML20042E050 | |
| Person / Time | |
|---|---|
| Site: | Dresden, Braidwood  |
| Issue date: | 03/05/1990 |
| From: | Cale Young AFFILIATION NOT ASSIGNED |
| To: | David Williams NRC OFFICE OF THE INSPECTOR GENERAL (OIG) |
| Shared Package | |
| ML20042E047 | List: |
| References | |
| NUDOCS 9004190114 | |
| Download: ML20042E050 (23) | |
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-262 Sheffield Lane Glen Ellyn, IL 60137 March 5, 1990 Mr~. David C. Williams Inspector General Office of the Inspector General U.S.
Nuclear Regulatory Commission Washington, D.C.
.20555
Dear-Mr. Williams:
Commonwealth' Edison's policy for operating nuclear-plant:
safety systems, permits an. operator to turn off emergency-core cooling pumps during an' emergency. Turning off emergency 4
pumps' pumping water into the reactor during a loss of' coolant-accident in a nuclear power plant,~ risks-damaging.the; reactor's nuclear fuel, release'of fission products, and exposure'of plant. personnel and-people. nearby to hazardous i
c radiation. Although sanctioned by the Nuclear Regulatory L
Commission, Commonwealth' Edison's policy is dangerous.
Commonwealth Edison first published this policy in VICE-
-PRESIDENT'S INSTRUCTION NO. 1-0-17, dated; october. 22, 1979.
I was serving as Compliance Administrator in. Commonwealth l
Edison's Nuclear Stations Division.at 'this time. I worked t
with:the company's nuclear stations to ensure compliance with
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the rules and regulations of the' Nuclear Regulatory Commission.
- L On' September 4, -1980, I submitted a DEVI ATION REPORT to I'_
Commonwealth Edison's President. I reported that our company-CI creates a substantial safety hazard in operating Zion, Dresden, and Quad Cities Nuclear' Stations. I cited the policy published in the VICE-PRESIDENT'S INSTRUCTION'.
Commonwealth Edison's President notified the Nuclear Regulatory Commission's Region-III.cof my DEVIATION REPORT.
The VICE-PRESIDENT'S INSTRUCTION was not-corrected, however.
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f About this time, I was relieved as Compliance Administrator and assigned to work in the Training Department-of Braidwood Station. Braidwood Station, aLnuclear station.about sixty miles.from Chicago, was then under construction. I reported to Braidwood on September 8, 1980.
The VICE-PRESIDENT'S INSTRUCTION dated October 22, 1979, authorizes an operator to shut-down-an emergency core cooling system if reactor coolant system pressures, temperatures, and levels are following expected trends. During a loss of coolant accident, emergency cooling is necessary if reactor coolant system pressure is below the emergency system's-9004190114 900409 gDR ADOCK0500pggo
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s' Initiation netpoint. Authorizing an operatorLto shut down' emergency core cooling pumps because-system pressures, temperatures and levels are following certain trends, risks rupturing fuel rods, and exposing plant. workers and people nearby to highly radioactive fission products.
On March 1, 1981, VICE-PRESIDENT'S INSTRUCTION NO. 1-0-17, was reissued. The phrase "following expected trends",1was i
eliminated._The Director of Nuclear Safety told me that the l
company President had ordered this. change to the INSTRUCTION.
On May 20, 1981, I attended a meeting in the of fice oi: an l
Executive Vice President. The Director of Nuclear safety.was l
'present We-discussed the VICE-PRESIDENT'S INSTRUCTION. I l
said that' stable reactor coolant system pressures,-
temperatures,-and leve,ls do not1necessarily mean that there is adequate core cooling. With reactor coolant system' pressure-stable-but low, and temperature stable but:high, nuclear fuel-can be burning _up.
I said it would be dangerous to turn off an emergency core cooling system under these L
conditions as authorized by_the INSTRUCTION..Despite this-l discussion, toward the end'of_the meetJng,:the Executive Vice President said to me that the INSTRUCTION stands as is.
g In a letter dated June 25,-the Executive Vice President L
confirmed that the company did not intend-to correct the VICE-PRESIDENT'S INSTRUCTION. I therefore wrote to the Director, Office of Inspection'and Enforcement, U.S.
Nuclear Regulatory Commission, Washington, D.C.,
pursuant to the-Code J
of Federal Regulations, 10 CFR 21.5. In my letter dated' July 2, 1981, I wrote that commonwealth Edison fails to comply; with the Atomic Energy Act of 1954, and the-Nuclear Regulatory Commission's Rules and Regulations, i
I wrote that the : company policy for operating nuclear-generating plants,. promulgated in VICE-PRESIDENT'S INSTRUCTION NO. 1-0-17 dated March 1, 1981, authorizes operators to withdraw a safety system from operation.
Withdrawing a safety system from operation constitutes a loss of safety function; a major reductionz in,the degree of-protection provided public health'and. safety. Withdrawing a safety system from operation creates a1 substantial safety.
s hazard as defined'in Part 21.3 (k) of the Rules and Regulations of the Nuclear Regulatory' Commission.
The Energy Reorganization Act of 1974, established a procedure.for reporting noncompliances to_the Nuclear Regulatory Commission. Section 206 paragraph (1), reads that-a responsible officer of a utility licensed to operate a nuclear power plant who obtains information indicating that the-utility falls to comply with the Atomic Energy Act of 1954, or any rule, regulation or license of the commission-relating to_ substantial safety hazards, shall immediately i
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1, notify the-Commission. The Code of Federal Regulations,-Part 21, implements this law by:
(1) Defining a substantial safety hazard-(2) Establishing procedures for reporting a' substantial safety hazard to the Nuclear RegulatoryLCommission (3) Requiring prompt corrective action-i Commonwealth Edison's policy is; dangerous.lThe INSTRUCTION.
' dated-August. 18,'1986, authorizes an operator to shut down emergency systems before the systems.have accomplished their1 design purpose. Following this: poll'cy during a loss of q
coolant accident, an operator can cause a nuclearrfuel i
meltdown by shutting down emergency. pumps. He~1s also-l authorized to-risk the integrity:ofca reactor's containment
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structure 1by turning off the containment ~ spray system before containment-pressure has been: reduced. By this policy, commonwealth Edison-risks a serious accident' releasing. highly radioactive fission products to the environment, and exposing plant personnel and people nearby-to. hazardous radiation.
I am enclosing copies of-my two Part 21 reports.
Sincerely'yours.
// is-f7 Charles Young i
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Sept aber 4, 1980
- Mr.! J. J. O'Connor The purpose of this letter is to infom you that our ccmpany creates a substantial safety hazard as defined by the Ccde ~of Federal Regulations Part 21.3 - (k), in the operation of Zion Stdtion's nuclear-plants.
I am infoming you of this in accordance with the Ccde of Federal.
Regulaticns Part 21.21 (a)- (2) (i) and Camenwealth Edison Ccr:pany _Presi-'
dent's Instruction No. 0-0-5.
We created a substantial safety hazard at Zion Station at approxistely
- 0830 February 2,1979, when an Operating Engineer, a licensed Senior.-Operator,.
in Unit 1 control room, with the reactor plant at approximately 25% pomr, disenabling or ordered disenabled, the safety injection systs. - Disenablirh -
the safety injection systs, a reactor safeguards system, with the reactor l-at power, resulted in the loss of a safety function-and a mjor reSuetion in the degree of protection provided the public health ard safety. 4 Dis-enabling the safety injection syst s with the reactor at power is a violation of Zion's Operating License and Technical Specifications.
One cordition required to actuate safety injection was present in the U
reactor coolant systs when the systs was disenabled on February '2,1979.
We created a substantial safety hazard at Zion Station frcn Septaber, i
1978 to May,1979 when Zion Unit One was-operated while incurring frequent-scrams. l V
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Durirg February, Mamh, and April,1979,. a major cmponent, a feedwater pmp, was malfuncticning and a number of scrams were attributed to abnormal-plant conditions caused by this feedwater pump.
On one occasion, Operators attributed abnormal plant conditions which caused a scram to the feedwater p2mp but' the abnomal conditions were caused by malfuncticning of another cmponent, a feedwater regulating valve.
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During this period, reactor startups were made without the cause of the:
scam preceding the startup having been accurately determined and corrected.
Zion Unit One scranmed 17 times-from Septenber 1978 to May 1979:
September 14, 1978-October 30, 1978 Novenber 2,1978 '
November 5, 1978 Decenber 4,1978 Decanber 7,1978
' February 1, 1979 February 2, 1979 March 2, 1979 March 5, 1979 March 16, 1979 March 21, 1979 Mamh 22, 1979 April 26, 1979 April'27, 1979 (two scrams-this date)-
May 23, 1979 Scrams on the following dates were attributed to malfunctioning of 1B feedwater pump.
February 1, 1979 March 2, 1979 March 5, 1979 March 16,1979 April 26,-1979 Three successive scrams in a tvo-week period' (March 2, 5, and 16) were caused by malfunctioning of 1B feedwater pump.
On April 26,1979, Operators thought that abnormal plant conditions which caused a scram were due to malfunctioning of 1B feedwater pump but the abnormal plant conditions were caused by a malfunctioning feedwater regulatirs valve.
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.Startups of the reactor plant wera made after scra:ns on the folicw ng dates wittout the cause of the scram having been accurately determined and corrected:
Investicjation of the cause of this scram was nade-September 14, 1978.
Cause of the turbine. trip and reactor scram could not on October 14, 1978.
be deternined at this time.-
Cause of scram trought by Operators to have been mal-April 26,1979.
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The cause was fourd to have been a mal "
functioning of 1B feo3 water pump.
functioning feedwater regulating valve on April 27, after the next scram.
The April'27 scram was also caused by the malfunctioning feedwater regulatin i
valve.
A second scram on this date was attributed by.the April 27, 1979.
Shift Engineer to the turbine DC system; hoever, the operating engineer i
attributed it to " Operator Perfornance."
operating Zion Unit one while incurrire frequent. scrams and with a frequently malfunctioning feedwater pump created a substantial safety hazard The judgnent of Operators regardirg the cause of abnormal conditions which occurred in the reactor plant during this-time was affected by the mal-functioning feedwater pump.
The Operator's capability to analyze and deal with-abnormal plant This situation caused a loss of safety function
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conditians was impaired.
j to the extent that there was a major reduction in the degree of protection s
provided public health and safety.
Starting up a Zion reactor plant without investigating to determine the cause of the scram ard correcting the cause is a violation of the Facility Operating License / Technical Specifications, the Canpany Quality 4
Assurance Program, ard Station Procedures.
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On April 5,1980 at 0231, Zion Unit 2 reactor scramed due to low water level in 2A stem generator- (with steam flow-feed flow mismatch). At 0615 the same day, Unit 2 reactor scrammed again due to low water level-in 2A steam generator (with stem flow-feed flow mismatch).
The startup b=Iore the 0231 reactor scram was made with 2A feedwater regulating valve malfunctioning. The operator attspted to control' water level in 2A steam generator by use of an isolation valve. He was unable to maintain the proper amount of water in the steam generator and the reactor scramed on lcw water level in 2A steam generator (with steam flow-feed flow mismatch).
The startup of Unit 2 reactor before the 0615 scram was made under the same corditions as the earlier startup.
2A feedwater regulating valve was mal-functioning and the operatar was attspting to control water level in 2A steam generator by use of an isolation valve. Again he was unable to main-tain the proper amount of water in the stem generator'ard the reactor.
scranmed on low water level in 2A steam generator- (with steam flow-feed flow i
i mismatch).
Starting up Zion Unit 2 about 0615 April 5,1980, with a malfunctioning-feedwater regulating valve, while attempting to maintain water-level in a steam generator by use of an isolation valve, a method which had caused a scram at 0231 the same day, is a violation of Zion Station's operating License /
Technical Specifications, the Ccnpany Oaality Assurance Program, and Station Procedures.
Operating Zion Station in violation of the Station's Operating License /
Technical Specificaticns, the Ccmpany Quality Assurance Program, and Station Procedures creates a substantial safety hazard--a major reduction in the degree of protecticn provided public health and safety.
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We contjaue to create a substantial safety hazard because Zion Station is being operated while incurring violations of the Operating License and Technical Specifications without taking effective corrective action to i
prevent recurrerce. Following are examples:
1.
Zion's Operating License and Technical Specifications require the reactor to be brought to hot shutdown immediately if two instrument inverters beccne inoperable. Two instrument inverters became inoperable at 0400 January 12, 1979 when Inverter No. 114 tripped with "O" diesel genera-tor out of service for maintenance. The Shift Engineer did not knw that 1
imnediate shutdown of the reactor plant was required in this situation.
The fact that immediate shutdown was required was realized at approximately 0645. Reactor shutdcun was not ccnmenced until 0750, howver.
2.
Zion's Operating License and Technical Specifications recruire %o soutrees of offsite Irwer to be lined up and available when the reactor plant l
is operating and one diesel generator is cut of service. One of two sources of Zion Unit 1 offsite power was made unavailable at 0815 March 12, 1979 with E diesel generator out of service for maintenance. This source of offsite power was unavailable for about 45 minutes.
3.
Zion's Operating License and Technical Specifications require two
-t hydrogen reccnbiners to be available for use with the reactor plant operating.
Only one hydrogen reccmbiner was operable frcm March 14, 1979 to April 12, 1979 because Unit 2 hydrogen reccmbiner was trade inoperable on March 14th. Unit 1 was operating during this period.
4.
Zion's Operating License and Technical Specifications reqaire three contaiment spray ptmps to be lined up for use when the reacter plant is operating. One of three Unit 1 contaiment spray pinps was not available for automatic operaticn on April 23, 1979 for about 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> because of' a switching error.
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Zion's Operating License and Technical Specifications require the reactor to be brought to hot shutdan immediately if two instrument inverters beccme inoperable. Two instrument inverters became inoperable at approxi-t mately 0615 August 11, 1979 when Inverter No.114 failed with "O" diesel.
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generator out of service for maintenance. The Shift Engineer did not know that inmediate shutdown of tM reactor plant was required in this situation.
Shutdown of the reactor was ccnmenced at approximately 0750. This error j
is similar to the January 12th error.
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6.
Zion's Operating License and Technical Specifications require that
- contalment integrity be naintained if positive reactivity changes are made-l by baron dilution of the reactor coolant system when' shutdown margin is l
less than 10%' delta K. Contrary to this requirement, Zion Unit 1 reactor K
l coolant systs was diluted frcm 2394 ppn baron to 1448 ppn boron with shut-dcan margin less than 10% delta K with primary containment open during the K
period December 4, 1979 to December 29, 1979.
7.
Contrary to the requirenent identified in paragraph 6, Zion Unit 2 reactor coolant system reactivity was also increased with shutdown margin less than 10% delta K by diluting the boron concentration with containment K
open. This dilution resulted frcxn malfunctioning of the boron dilution-
- system. Facts regarding this Technical Specification violation incitriing the date of occurrence are vague. The violation is reported in the same repor_t as the Unit 1 violation. Proper reporting requires (1) the Unit 2 violation.
be reported separate frcm the Unit 1 violation, and (2) nore details be reported.
8.
Zion Operating License and Technical Specifications regaire that a reactor plant be brought to hot shutdown imnediately if two diesel genera-tors becone inoperable. At 1720 April 8,1980, two diesel generators for l
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Zion Unit 2~ became iroperable but the reactor plant was not brought to hot shutdcur.,
9.
Zion's Operating License ard Technical Specifications require that reportable occurrences, including corrective acticns ard measures to prevent recurrence, be reported to the Nuclear Regulatory Ccmnission. Abnormal degrada-tions of systems designed to contain radioactive material resultire frcan the fission process are identified as abnormal occurrences in Zion's Operating License and Technical Spe:ifications.
On April 30, 1979, 700 gallons of radioactive water were spilled on the floor of the Zion auxiliary building. No report which included corrective action and measures to prevent recurrence was made to the Nuclear Regulatory ccnmission.
On May 12, 1980, 10,000 gallons
- of radioactive water flooded the reactor containment building of Zicn Unit 2.
No report which included corrective action ard measures to prevent recurrence was made to the Nuclear Regulatory Ccumission.
On March 31, 1980, 700 gallons of radioactive water was transferred by mistake frcm the volume control tank of Zion Unit 2 to an equipment drain tank in the auxiliary building. The radioactive water in the equipnent drain tank caused airborne radioactivity in the auxiliary building. No report which incitded corrective action and measures to prevent recurrence was made to the Nuclear Regulatory Ccmnission.
- 10. Zion Operating License / Technical Specificaticns require that two hydrogen purge fan systens be operable when the reactor is critical. Only one hydrogen purge fan systen was operable ccmnencing August 15, 1980.
Both Unit 1 ard Unit 2 reactors were critical on this and succeeding dates.
- Reported by the press. Also reported as 3 to 4,000 gallons by the press.
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Folloairs is additional evidence of our inability to take effective corrective action to prevent recurrence of errors at Zion Station:
Radioactive liquid was spilled while beirg transferred frcrn Zion's 1.
rad waste building to a shipping cask on a trailer causirg contantination of 'an area inside and outsideL the building, the shipping cask, and the
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trailer. Spills oo:urred on the following dates:
June 28, 1978 February 2,1979 Atgust 8,1979 In July 1979, Zion Unit One's Operating License ard Technical 2.
Specifications required that. hot channel factor surveillance be corducted at least every ten hours when the Axial Power Distribution Monitoring
~t At this time, Station Procedures required that this Systen is inoperable.
surveillance be conducted every eight hours.
the interval between hot channel factor surveillances On July 18, 1979, The' interval was twelve exceeded that required by Technical Specifications.
s The Operating. Engineer knew that' this error'had hours aM forty minutes.
occurred before yet again, on July 30, 1979, the interval between hot channel factor surveillances was eleven hours twelve minutes.
Weekly surveillances required to be condteted on October.10,1979 3.
a 15, 1979 because by Station Procedure Pr201 were not conducted until October the schedule was overlooks 3.
This is a Technical Specification violation also.
Weekly surveillances required to be conducted on November 11, J 979 4.
19, 1979 because by Station Procedure PT201 were not conducted until Novenber This is a Technical Specifi-of being overlooked during a heavy work load.
cation violation also, i
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5.: A surveillance of the gas decay tank required each shift by Zion's t
l Operating License /rechnical Specifications paragraph 6.6.2a (2), ard L
Station Procedure PT 14, was missed during the 2300 to. 0700 shift on December 6 and 7, 1979.
6.
On February 2,1980, during the' out of service surveillance of containment particulate radiation monitor 2 RE-0011, no grab sample was I
taken between 0700 and 1500 as was required (Unit 2).
7.
On February 24, 1980, scheduled surveillance PT-3D,' testing of main steam isolation valves was missed:ard conducted two days late.- This is a-Technical Specification violation.
-8.
On April 12, 1980,- the surveillance end date for Pr10A and B, Zion Unit 1, was missed. The grace period of this test was exceeded by L
ten days.
9.
On April 18, 1980, Zion Unit 2 2B purge fan damper ~ failed to stroke open on a test. The other fan was tested and performed satisfactorily.
A daily surveillance instituted by the Station was missed on the next two I
days.
- 10. On June 16, 1980, the a::ount of fuel oil in the fuel oil storage tank for Unit 1 diesel generators was less than reqaired by the Operating License /rechnical Specifications.
- 11. On June 16, 1980, the interval between hot channel factor surveil-lances, Zion Unit 1, exceeded the interval required by Technical Specifica-tions. When the surveillance was conducted, the surveillance was conducted improperly.- (Reported by Unit 2 Operating Engineer.)
- 12. On June 18,1980, while in the refueling mode, Zion Unit 2 did not have the low temperature overpressure protection required by the Operating License /rechnical Specificatiolu.
(Reported by Shif t Engineer.)
.. 13. On June 27, 1980, Zion Station discharged radioactive water frm the Lake Discharge Tank to Zion Unit 2 canal instead of Unit 1 canal as required by the authorization for this discharge. The discharge lasted for about one' hour.
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- 14. On July 25,1980, at 2125, Zion Unit 2 reactor scra:med frm a power level of 170 FH on low level in 2B steam generator (with steam ficw-I feed flw misnatch). Tne main turbine autamtic control systs was inopera-tive causing probims in maintaining steam generator level control, according to the Responsible Supervisor and the Operating ' Engineer.
On July 26,1980, at 2120, Zion-Unit 2 reactor scramed frm a power level.of 520 FM on low level in 2A steam generator (with steam flow-feed flow misnatch). The main turbine autmatic control system was still.tnopera-l tive and one steam flow channel for 2A steam generator was also inoperative, according to the Responsible Supervisor and Operating Engineer.-
- 15. On July 23, 1980, at 0650, Zion Unit 2 had an inadvertent safety 1
injection frm Safeguards Train B during startup of the reactor.
The safety injection was caused by an Operator using a new Procedure which did not work and the old Procedure no longer existed, according to the 1
l Operating Engineer.
At about 1700, during the startup, the temperature of the. reactor 0
coolant system increased above 200 F with Safeguards Train A still in test. 'nechnical Specifications and Station Procedures require that all Safeguards systes be operational (out of test) when reactor coolant temper-0 ature is increased above 200 F.
The problEG was the long time required to take Safeguards Train A out of test because of problems with the new Procedure, according to the-Operating Engineer.
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- 16. On August 13, 1980, at approximately 0640, Zion Unit 2 exceeded l
l maxinum reactor power by about 2% (indicated power level 102.2%) for a l
short period due to a problem with the turbine autaratic control system.
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- 17. On August 3, 1980, 6000 gallons'of radioactive water was p eped by mistake fran Zion Station OA Lake Discharge Tank to Lake Michigan.
- 18. On October 14, 1979, Zion Unit 2 turbine generator tripped while being shut down due to loss of vacuum. After investigation, the loss of-vacuum was determined to have been caused by an open valve linking Zion-I l
Unit 1 to Zion Unit 2.
Unit 1 was shut dom in a refueling outage; on April 1,1976, Zicn Unit 2 turbine generator bearings failed due L
to overheating of turbine oil. Turbine oil ovesheated because Unit 2 l~
service water systs was isolated whenit was interded to isolate Unit 1 service water systs. Unit 1 was then in a refueling outage.
Repairs to Zion Unit 2 at this time were costly ard lengthy.
Following are docunents which relate to these matters:
(1) Mmorandun C. Young to Frank Palmer, dated March 20, 1979, subject Blocking of High Steam Flow Safety Injection at Zion, Fehn2ary 2,.
1979.
Copy sent to Mr. W. J. Shewski, Manager of Quality Assurance.
(2) Memorandum C. Young to Frank Palmer dated May 22, 1979, subject Scrams at Zion Staticn.
L (3) Menorardtra C. Young to W. B. Behnke, dated May 11, 1979. This menorardun written as a follow-up to a neeting between Mr. Behnke and C. Young, contains ccmnents and reccanerdations regarding the company's
- attitude toward nuclear operations.
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(4) Menorandum by C. Young dated May 21, 1979, subject Reactor Scrams I
at Zion Station. Copy sent to Mr. W. B. Behnke, Dcecutive Vice President and Mr. W. J. Shewski, Manager Quality Assurance.
(5) Mestorardum C. Young to W. B. Behnke dated May 29, 1979. Follcw-up to other matos.
(6) Menorardum C. Young to Byron Lee Jr. dated June 13, 1979.
Menorandum contains C. Young's recomendations for. improving the operations of Zion Station requested by Mr. Lee at a meeting June 5, 1979. Attached to the merrorardum is a. Study of Zion Station Operations to support the--
reccrimendations. The study consists of Conclusions, Station Objectives, Statement of Proble,' and Analysis of Problem.
(7)- Mamorardum Charles Young to Mr. J. J. O'Connor dated January 29, 1980.
(8) Mmorards C. Young to D. Galle dated March 11, 1980; subject Professionalim Investigation of Zion Containment Integrity Proble.
(9) Menorardum C. Young to D. Galle dated May 2,1980; May 22,1980; l
May 27, 1980. Subject Missed Surveillances at Zion Station. Copy to Quality Assurance.
(10) Menorards C. Young to D. Galle dated May 23, 1980.
Subject l.
Diesel Generator Problems at Zion, April 1980.
(11) Mercrardum C. Young to Mr. J. J. O' Con:or, July 9,1980.
Subject Follow-up to July 9 Meeting.
(12) MeTorardum C. Young to Cordell Reed, July 15, 1980. Subject Follow-up to July 10 Meeting.
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This letter also informs you that we create a substantial' safety hazard as defined by the Code of FMeral Regulations Part 21.3 -(k), because our Company Policy set forth in Vice President's Instruction ?b.1-0-17 dated October 22, 1979, grants authority to licensed operators a M senior operators to operate the-Cmpany's nuclear facilities in violation of the Facility Operating License aM Technical Specifications.
I am informing you of this in accordance with the Code of Federal Regulations Part 21.21 (a)- (2) (i) aM Camonwealth Edison Cmpany Presi -
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dent's Instruction No. 0-0-5.
Vice President's Instruction No. 1-0-17 gives authority to an Operator in conjunction with a licensed Senior Reactor Operator, or a Senior Reactor l
Operator alone, to operate a Carmonwealth Edison nuclear plant outsice Technical Specifications to prevent:
(1) personnel injury, (2) off-site 1
releases above Technical Specification limits, (3) damage to equipnent.
I Technical Specifications stipulate safety limits', safety systen settings, and operating coMitions based on plant design. The plant is designed to i
prevent release of radioactivity and injury to-personnel.
Safety limits, safety systen settings, and operating coMitions stipulated in Technical Specifications'are selected to prevent release of radioactivity and injury to personnel. Operating outside these limits, coMitions, and safety system settings,as permitted by the Vice President's 1
Instruction, would create a substantial safety hazard--a loss of safety
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function to the extent that there is a major reduction in the degree of protection provided public health and safety.
f Safety limits, safety systen settings, and operating conditions stipulated in Technical Specifications are selected to prevent release of radio-i activity aM injury to personnel. The Vice President's Instruction permits operating outside of thase limits, conditions, aM safety systan settings u-w
.t 14 to prevent damage to equipnent. Operating outside of these limits, conditions, and safety systen settires creates a substantial safety hazard--a loss of safety functicn to the extent that there is a major reduction in the degree of protection provided public health and safety.
Reactor plant equipnent is designed to operate under conditions specified in the Technical Specifications and is protected against damage by safety devices.
It is not likely, therefore, that operating outside Technical Specifications would prevent damage to equipnent.
Safety systens are. required by Technical Specifications to cperate after initiation because safety systens are designed to prevent release of radioactivity and injury to personnel during a reactor plant accident.
Vice President's Instruction No.1-0-17 permits an operator to with-draw a systan fran use if radiation levels and the pressure and tempera-ture in the primary contairrient are stable or following expected trends.
I The Vice President's Instruction also permits an operator to withdraw a systen fran use if core cooling is adequate as indicated by stable reactor
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coolant systen pressures, temperatures ard levels or if these parameters are following expected trerd3.
An activated safety system is required by Technical Specifications to reuain in operation as long as the activating condition persists.
Withdrawing a safety systen while the activating condition persists as permitted by the Vice President's Instruction, muld create a substantial safety hazard--a loss of safety function to the extent that there is a
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major reduction in the degree of protection provided public he.alth and safety.
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. This letter also informs ycu that cur Ccnpany creates a substantial safety hazard in the operaticn of Dres$en ard Qaad Cities Stations when the i
reactor prirary contairrnents of Dresden Units 2 and 3 ard Quad Cities Units 1 ard 2 are deinertoS with the reactor at power to permit entry of per-sannel to work on machinery and equip:ent. Deinertire the prinary contain-ment durire reactor pcwer operations is a violation of the operating License /
Technical Specifications of DresSen Units 2 ard 3 ard Oaad Cities Units 1 and 2.
I am informing ycu of this in accordance with the Code of Federal Regulations Part 21.2 (a) (2) (i) ard Ccrmonwealth D31 son Campany President's Instruction !b. 0-0-5.
Er.amples are:
Dresden Unit 2 July 28,1979 Janaary 15, 1979 January 14, 1979 lbvsnber 25, 1978 lbvember 20, 1978 Quad Cities Unit 1 i
Septenber 1,1979 June 9, 1979 March 3, 1979 September 4, 1978 August 23, 1978 Ouad Cities Unit 2 May 8, 1980 July 24,1979 August 3, 1978 This letter informs 3ou that cur Ccmpany cculd create a substantial safety hazard because of the manner in which we operate Dresden Station's nuclear plants.
I am informirg you of this in accordarce with the Code of Federal Regulations Part 21.2 (a) (2) (i) and Ccrnonwealth D3ison Ccnpany President's Instructicn Ib. 0-0-5.
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'.'o 16-Dresden Station Pro:cdures require that essential ecpipnent and systens be lined up and operatirg properly before starting up the reactor t
plant. Dresden Station Facility Operating License /rechnical Specifications require that Station Proccdures be adhered to.
On April 25, 1979, folicwing a transformer replacement, Dresden Unit 3 reactor was started up with Unit 2 250 volt battery ret operable. Unit 2 250 volt battery is required to be operable before starting up Unit 3 by the Facility Operating License / Technical Specifications. The error was identified on April 27; thas Unit 3 was operated for ab:)ut two days with an improper 250v battery line up.
In Deceber 1977, another error occurred on start-up of a Dresden reactor. On December 6,1977, Dresden Unit 2 reactor was started up and o
operated for about a day ard a half with the Lw Pressure Ccolant Injection Systan not fully operable. The Lcw Pressare Coolant. Injection was required to be fully operable by the Facility Operating License /rechnical Specifi-1 cations. An improperly positioned breaker would have prevented Irw Pressure Coolant Injection valves fran positioning if an activate signal had cccurred under certada loss of pwer conditicns.
Failure to line up safety systens and equignent in accordance with requirenents in these two instarces indicates potential for similar failures durirg future start ups. Starting up and operating a reactor plant with an improperly lined up safety systen could create a substantial safety ha::ard--loss of a safety functicn to the extent that there is a major re-duction in the degree of protecticn provided public health and safety.
The folicwing pertains to this problan
. Menorardum dato3 May 24,1979, by C. Yourg.
Subject:
Start Up Errors at Dresden Station. This manorardum was sent to Mr. F. A. Palmer, Dresden Marager, Naclear Stations anS Mr. W. J. Shewski, Manager Oaality Assurarce.
17 This letter also infoms you that our Ccrnpany oculd create a substantial safety hazand because of the manner in which radiolcgical incidents involving Ccrmonwealth D31 son Ccrnpany's Generating Station Dnergency Plan are hardled at Quad Cities Station.
I am infoming you of this in accordance with the Ccde of Federal Regulations Part 21.21 (a) (2). (i) and Ccimonwealth Diison Company President's Instruction !b. 0-0-5.
On March 19, 1979, Quad Cities Station was notified that a radioactive material shipnent of solidified potentially contaminated waste oil was laaking at a shipping teminal in Joplin, Missouri. A 55 gallon drum of improperly solidified waste oil frcrn Quad cities Station had been punctured in the loading prccess ard was leaking at the terminal.
Ccrmanwealth Blison Generating Station's Dnergency Plan Section 4.1.3 and the cuad Cities Dnergercy Plan Procedures reqaired that the Diergency Plan be implemented (offsite alert) because a radioactive waste shipnent was interrupted, spillage ard suspected contamination occurred, and control of an area was instituted. Ibwever, the Dnergercy Plan was not implementa3; an off-site alert was not called.
Implenentation of the Generating Station's Dnergen:y Plan, in addition to ensuring that appropriate measures to control the radioactive shipnent were taken, would have informed Federal Goverment, State and local authorities of the leaking drum of radioactive material.
Failure to implement Ccrnnonwealth D3ison's Generating Station's Dner-gency Plan in this instance indicates potential for similar failures in -
the future. Failure to impicment Ccrmonwealth D3ison's Generating Station's Dnergercy Plan when required could create substantial safety hazard--loss I
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of a safety function to the extent that 'there is a major reducticn in the j
degree of protecticn pawided public health and safety,
{! hit,ba Charles Yoang Canpliance A&ninistrator
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