ML20155A743

Discusses Safety Problems at Comm Ed Nuclear Power Plants Re Risking Fuel Meltdown by Turning Off Safety Sys as Directed by Util Policy in Emergency If Core Cooling Is Adequate. Vice President Instruction Encl

ML20155A743
Person / Time
Site:	Dresden, Quad Cities, 05000000
Issue date:	02/24/1988
From:	Cale Young AFFILIATION NOT ASSIGNED
To:	Weil C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20155A665	List: ML20155A659 ML20155A743
References
FRN-53FR36338, RULE-PR-50, RULE-PRM-50-50 NUDOCS 8810060057
Download: ML20155A743 (4)

Text

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262 Sheffield Lane Glen Ellyn, IL 60137 February 24, 1988 Mr. Charles H. Weil Investigation and Compliance Specialist U.S. Nuclear Regulatory Commission, Region !!!

Post Office Box 2027 Glen Ellyn, Illinois 60138-2027 Dear Mr. Weilt My letter of January 29, 1988, describes two safety problems at commonwealth Edison nuclear power plants. The first -

working employees near a nuclear reactor producing power -

occurs at Dresden and Quad Cities Stations. Risking a fuel meltdown by turning off a cafety system, can occur at any Commonwealth Edison nuclear power plant.

The Energy Reorganization Act of 1974, places responsibility for safety on officers of companies operating nuclear power plants. Section 206 of the Act reads that an officer of a firm operating a nuclear plant who learns of a plant defect which could create a substantial safety hazard, shall immediately notify the Nuclear Regulatory Commission.

A Commonwealth Edison Company Policy authorizes operators to turn off a safety system in an emergency if core cooling is adequate. The Policy states that core cooling is adequate if reactor coolant system pressures, temperatures, and levels are stable. But stable reactor coolant system pressures, temperatures and levels do not mean that core cooling is adequate.

With reactor coolant system pressure stable but low, temperature stacle but high, and level stable but low, the reactor's nuclear fuel can be burning up.

An operator at any Commonwealth Edison nuclear power plant can cause serious damage by f ollowing instructions issued by Company officers. Turning off water being pumped into a nuclear reactor by a safety system before the system has finished its job, can cause the meltdown of a reactor's nuclear fuel.

A copy of the defective Policy is enclosed. I have underlined one of the defects in the Policy.

very respectfully, ea 100600 300';o3""

ft L

't -m g",j%un Charles Young Enclosure 1

Copy to:

Mary 3. Bushnell, Chairman Illinois Commerce Commission Illinois Department of Nuclear safety Lando tech, Chairman U.S. Nuclear Regulatory Commission 2

O Commonwealth Edison Company 9

VICE FRESIDENT'S INSTRUCTION NO.1-0-17

$UBJECT:

Company policy Regarding Safe

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Operations and Adherence to Nuclear Procedures and Technical Specifications Effectivet August 18. 1986 Cancels:

V.P. Instn 1-0-17 (5-23 8n i

This Instruction reaf firms Company policy regarding adherence to nuclear procedures and technical specifications.

The primary concern of the Company with respect to the operation of its nuclear generating plants is to ensure the health and safety of the public as well as station personnel. All personnel within the Company share this responsibility.

In particular, it is the primary responsibility of the Station Shift Engineer to maintain safe plant operation since it is he who has direct control over all plant operations during his shift.

In order to achieve this saf ety goal, plant operation is to be within the boundaries specified in our technical specifications and in adherence to preceifures and operating orders. Systems which could affect the public tealth and safety (including energency core cooling system, rad-waste, etc.) are to remain operable as prescribed in the technical specifications.

It is recognized that circumstances may arise which were cot foreseen in the preparation of technical specifications.

yor example, a combination of events which were analysed individually say, taken together, produce results which were not

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espected or analysed during reviews leading to the technical specifications. In these rare, unforeseen circumstances literal adherence to the technical specifications may cause, rather than prevent, problems.

If such circumstances should arise, prudence may require operation outside of the technical specifications. procedures, or operating orders. This should be done only when necessary to solve an fiasediate probles and only after careful cohsideration and approval by the Station Shift Engineer or if there is insuf ficient time to contact him, the licensed Senior Rea : sr Operator immediately available in order to prevent (1) injury to the public or Company personnel (2) releases of f-site above technical specification limits, or (3) damage to equipment. if such damage is tied to a possible adverse effect on public health and safety. This operation should only be done when no action consistent with license conditions and technical specifications is immediately apparent which can provide adequate or equivalent protection.

Further. it may be necessary upon occasion to tensorariiv withdraw a avatan or systems froe operation by elseina it in a manual or sull-to-lock mode. Thi t. shouir be done only when conditions are "stebte and under control". or when it ta apparent that continued operation would aggravate er worsen the plant condition. The conditfor of "stable and under control" are considered to exist (1) if the radiation levels and the pressure and temperature in the primary containment are stable sad (2) if there is adequate core coolina as indicated by stable reactor coolant systen pressures.

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temperatures and levels.

In all instances such action should be taken only af ter caref ul consideration, and it must be reviewed and approved by the licensed Senior Reactor Operator immediately available.

It is not expected that such operations will be conducted for prolonged periods.

I 111. C. C. Docket 87-0228 Exhibit A

(4-14 86)

Whenever a systes is withdrawn from cperation as outlined, continuing surveillance of the relevant parameters must be maintained by a licensed Reactor operator to assure the safe operation of the plant until the systes can be restored to normal operability or until it is no longer needed, as prescribed by the technical specifications.

In all cases noted above, when the technical specification boundaries are cuceeded or when a system is withdrawn from operation:

The Station Shift Engineer shall te notified immediately.

The Shift Technical Advisor / Station Control Roos Engineer shall be consulted to determine whether immediate shutdown, orderly power reduction, or other course of action is appropriate.

The Station Manager or his designate shall be notified who in turn shall notify the Nuclear Duty Officer in accordance with established procedures.

The NAC Operations Center shall be notified by telephone. When time permits, the notification must be made before the protective action is taken otherwise, the notification must be made as soon as possible thereafter.

A report shall be promptly made to the Division Vice President -

Nuclear Stations.

A plant shutdown tamediate or by power reduction, shall be cessmenced unless prolonged operation under the circumstances is concurred in by the NRC in the case of operating outside the technical specifications.

In other cases the Station Manager or his designate may authorite prolonged operation if appropriate.

All station personnel shall be informed of this policy and it shall be included in our training progras.

On-Vice President ee e