ML20155A659

Comment Supporting Petition to Rescind Paragraphs (X)(Y) of Section 10CFR50.54 Re Cases of Hazardous Practices Including Util Authorizing Senior Operator to Turn Off Safety Sys in Emergency Before Sys Has Finished Job

ML20155A659
Person / Time
Site:	Dresden, Quad Cities, 05000000
Issue date:	09/03/1988
From:	Cale Young AFFILIATION NOT ASSIGNED
To:	Clausenk M NRC COMMISSION (OCM)
Shared Package
ML20155A665	List: ML20155A659 ML20155A743
References
FRN-53FR36338, RULE-PR-50, RULE-PRM-50-50 53FR36338-00001, 53FR36338-1, AC26-2-09, AC26-2-9, NUDOCS 8810060035
Download: ML20155A659 (2)

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3 262 o alen Ellyn, II. 40r77 September 3, 1988 t rn.,,

g Mr. Max J. Clausen t.0Ci.i "1,.,*,

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Senior Technical Assistant to Chairman Zech s

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Nuclear. Regulatory Commission Washington, Dsc.

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Y I appreciate your sending me a copy of the petition which gaa.

requests that the NRC rescind paragrapha (x) and (y) of Section 50.54 of Part 10 of the Code of Federal Regulations.

Paragraph II, Grounds for the Petition, reads:

"The petitioner cites several cases of hazardous practices where, the petitioner asserts, the licensee has violated Federal Regulations at the Dresden and Quad Cities Nuclear Power Plants, owned by Commonwealth Edison Company, Chicago, Illinois. The petitioner believes that these practices could lead to an accident similar to the one at Three Mile Island, Unit 2.

My April 18 letter describes how Commonwealth Edison's Policy for operating nuclear power plants can cause a nuclear fuel meltdown - an accident like Three Mile Island (page 2, next to last paragraph). It is this Policy that can lead to an accident like Three Mile Island.

Commonwealth Edison's Policy for operating nuclear power plants is published in a Vice President's Instruction. This Instruction authorizes a Senior Operator to turn off a safety system in an emergency before the system has finished its job. Turning off a nuclear plant safety system in an emergency before the system has finished it job, can lead to an accident similar to the one at Three Mile Island, Unit 2.

During Proceedings btfore the Illinois Commerce Commission on September 15, 1987, commonwealth Edison's attorney cited 10 CFR 50.54 paragraphs (x) and (y), as authority for this Policy. The Policy applies to all of the Company's nuclear power plants. Thus Commonwealth Edison risks an accident like the accident at Three Mile Island Unit 2, at twelve nuclear power plants.

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I am enclosing a copy of my February 24, 1988, letter to Mr.

Weil, Investigation and Compliance Specialist, in Region III.

This letter contains a copy of Commonwealth Edison's defective policy.

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a Thanks again for your letter.

i Sincerely yours, i

El+ l m Charles Young i

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