ML20206D992

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Urges NRC to Cancel Federal Regulation Permitting Licensee to Depart from Tech Spec When Operating Nuclear Power Plant in Emergency & Ensure That Util Promulgate Policy to Operate TMI Unit 1 in Accordance W/Ol & Tech Specs
ML20206D992
Person / Time
Site: Three Mile Island, 05000000
Issue date: 05/03/1984
From: Cale Young
AFFILIATION NOT ASSIGNED
To: Palladino N
NRC COMMISSION (OCM)
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NUDOCS 8811170348
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L 262 Sheffield Lane  !

Glen Ellyn IL 60137 l 1 (312)790-2288

May 3, 1984 l

i Dr. Nunzio J. Palladino Chairman [

U. S. Nuclear Regulatory Comission

Dear Mr. Chairman:

You are endeavoring to provide assurance that Three Mile Island Unit 1 l

will be operated safely. Before issuir m Operating License, you want to be ,

sure that General Public Utilities Nucle *orporation's executives will  ;

operate Three Mile Island Unit 1 to generate electric!ty and not cnaanger i public health and safety.

I You changed Federal Regulations after the Three Mile Island accident. l Now, a senior operator in a commercial nuclear power plant is to deviate from  !

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technical specifications in an emergency. In an emergency, a sento* operator >

l is to devise action to protect public health and safety if it is not immedi- t ately apparent that following technical specifications provides protection. [

The nuclear plant operator at Three Mile Island deviated from technical  !

specifications at the beginning of the accident. The operator turned off an I emergency signal and shut down the emergency core cooling system. The shift  ;

I supervisor, a senior operator, permitted the nuclear plant operator to deviate from technical specifications to shorten plant down time. The shift supervi-  :

sor was working to get the nuclear plant back on line as soon as possible. l Before the accident, the station manager and his, supervisors deviated )

from technical specifications and kept the Three File Island nuclear plant on ,

line generating electricity for Metropolitan Edison Corpany. The electro-

nagnetic relief valve started to leak several months before the accident.

Supervisors kept the block valve open. The relief valve was leaking badly l several days before the accident. Supervisors operated three reactor plant [

l systens abnormally to overcome problems caused by the reactor coolant system l

1eak, f During the first day of the accident, action devised by Three Mile t Island's anagers, supervisors, and operators to cool the nuclear fuel  !

deviated from tecanical specificatiora. At least six senior operators devised  ;

action to cool the nuclear fuel. None was successful and the nuclear reactor l boiled out of control all day.

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Or. Nunzio J. Palladino May 3, 1984 Page Two Reactor coolant system pressure was below the setpoint of the emergency core cooling system most of the morning and all afternoon. Technical speci-fic.ations required emergency pe'nps to pump water into the reactor and coolant pumps to circulate coolant through the reactor core.

Late in the afternoon, a Babcock and Wilcox manager recomended ti tt emergency core cooling pumps pump fou, to five hundred gallons of water )er minute into the nuclear reactor. The General Public Utilities vice-pres dent for generation discussed the situattor, with the Metropolitan Edison vice-president for generation. The two executives decided that water should be pumped into the nuclear reactor. Metropolitan Edison's vice-president gave the order to the station manacer. ~

Operators shut the block valve for the electromagnetic relief valve and started pumping water into the nuclear reactor at five twenty-three p.m. As rtactor coolant system pressure increased, the station manager, in consulta-tion with Babcock and Wilcox engineers, made plans to start a reactor coolant pump. At seven-fifty p.m. , reactor coolant pump 1A was started. ,

At eight p.m., reactor coolant pump 1A was pumping water through the '

nuclear reactor and a steam generator to remove decay heat from the nuclear fuel. The steam generator was steaming to the main condenser. Cool down of Three Mile Island's nuclear reactor had commenced. Operators were operating the Three Mile Island nuclear plant to remove decay heat from the reactor and '

cool the nuclear core as engineers had designed the plant to be operated.

Engineers design commercial nuclear power plants to keep fuel rods intact and prevent release of radioactive material to protect public health and safety. Technical specifications are rules for operating a comercial nuclear l

i 4 power plant developed from the plant design. Technical specifications are rules for operators to follow during normal operitions and emergencies to operate the nuclear plant as designed.

Operators following a commercial nuclear power plant's technical speci-fications confine radioactive fission products within the fuel rods of the reactor core and prevent the release of radioactive material. Operators  !

operating a comercial nuclear power plant in accordance with technical specifications during normal operations and emergencies protect public health i and safety. l j 1 urge you and your colleagues to cancel the federal Regulation wh;ch i permits a licensee to depart from technical specifications when operating a nuclear plant in en emergency. I urge you to tell the president of General i

Public Utilities Nuclear Corporation that you expect him to promulgate policy i liial Ti..cc M;1e Is16ad Unit 1 is to te operated in accoruance with the Operat-ing License and Technical Specifications.

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Dr. Nunzio J. Palladino May 3, 1984 Page Three l

I urge you and your colleagues to have Nuclear Regulatory Comission inspectors inspect Three Mile Island Unit 1 to verify that the president of General Public Utilities Nuclear Corporation has implemented policy that operators are O operate Three Mile Island Unit 1 in accordance with the Oparating License and Technical Specifications. I urge you to instruct the Nuclear Regulatory (. omission staff to have an inspector inspect Three Mile Island Unit I daily. Have the Nuclear Regulatory Comission inspect daily to verify that Three Mile Island Unit 1 is being operated in accordance with the Operating License and Technical Specifications. Have an inspector inspect daily ann report resalts to the Regionc1 Administrator.

Since:ely yours, Charles Young Copy to:

John F. Ahearne, Ccmissioner U.S. Nuclear Regulatory Corraission Washington, D.C. 20555 Thomas M. Roberts, Comissioner U.S. Nuclear Regulatory Cornission Washington, D.C. 20555 Victor Gilinsky, Comissioner U.S. Nuclear Regulatory Comission Washington, D.C. 20556 James K. Asselstine, Cornissioner U.S. Nuclear Regulatory Comission Washington, D.C. 20555

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262 Sheffield Lane Glen Ellyn, IL 60137 (312)790-2288 June 14, 1984 Dr. Nunzio J. Palladino Chairman U.S. Nuclear Regulatory Commission Washington, DC 20555

Dear Mr. Chairman:

When Three Mile Island's Unit 2 nuclear plant operator turned off the ,

emergency safeguards signal and shut down the emergency core cooling system at the beginning of the accident, he lost the safety functions of two reactor plant safety systems. Abundant cooling water to transfer heat from the reactor core was not provided because the operator shut down the amergency pumps. The protection system sensed the accident condition but could no longer initiate the emergency core cooling system because the operator turned off the initiating signal.

After the safety systen sa'ety functiers were lost, reactor coolant system pressure contir.ued to decrease and reactor coolant temperature in-creased. Safety limits were e>ceeded and fuel cladding fractured. Exceeding safety limits breected a physical barrier designed to guard agairst the uncontrolled release of radioactivity and protect public healt.' and sa'ety against the hazards of nuclear radiation.

When the Three Mile Island's nuclear plant operator departed from techni-cal specifications by turning off the emergency shfeguards signal and shutting the emergency core cooling system, he created a substantial safety hazard, a "loss of safety function to the extent that there is a major reduction in the i degree of protection provided public health and safety."

"Substantial safety hazard" is defined in the Code of Federal Regu-lations, 10 CFR 21.3 (k). Protection system safety functions are outlined in Criterion 20; energency core ccoling safety functions in Criterion 35.

Criterion 20 and Criterion 35 are two of the "General Design Criteria for Nuclear Power Plants," Appendix A to 10 CFR 50. Safety limits for nuclear reactors are defined in 10 CFR 50.36 (c)(1). Reactor core safety limits for Three Mile Island's nuclear reactor are defined in paragraph 2.1, "Three Mile Island Nuclear Station Unit 2 Technical Specifications."

An operator created a substantial safety hazard at Conconwealth Edison Company's Zion Unit I nuclear plant the morning of February 2,1979. With the reactor at 25! power, an operating engineer, a licensed senior operator, deviated f rom technical specifications and turned off the safety injection system. An abnormal plant condition had given a start signal to the safety injection system. A second signal would start the safety injection system and shut down the reactor. The operating engineer told me he turned off the safety injection signal because he thought he had the reactor plant under control and he wanted to keep the plant on line generating electricity for Co.nonwealth Edison.

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' Dr.. Nunzio J. Palladino Page 2 i 0

Three times in the past I infomed authorities that authorizing a senior operator to deviate from technical specifications when operating a commercial nuclear power plant creates a substantial safety hazard. I infomed author-ities as required by the Ccde of Federal Regulations,10 CFR 21.

I informed Mr. James J. O'Connor, President of Commonwealth Edison Company, Chicago, Illinois, that Comonwealth Edison Company creates a sub-stantial safety hazard operating the company's nuclear power plants: 1 informed Mr. O'Connor that Comenwealth Edison creates a substantial safety hazard by company policy which permits a senior operator operating a nuclear plant to deviate from technical specifications. Comonwealth Edison Company VICE- PRESIDENT'S INSTRUCTION No. 1-0-17 dated October 22, 1979, pemits a senior operator to deviate from technical specifications and withdraw a safety systen from operation. I inforr.ed Mr. O'Connor by a Comonwealth Edison DEVIATION REPORT dated September 4,1980, that Comonwealth Edison creates a substantial safety hazard operating nuclear power plants at Dresden, Quad Cities, and Zic.. stations. '

I notified Mr. Victor Stello, Director. Of fice of Inspecticn and Enf orce- i ment, U.S. Nuclear Regulatory Comission that Comonwealth Edison Company creates a substan\ial safety hazard operating nuclear plants at Dresden, Quad Cities, and Zivo notiuhs. I notified Mr. Stello that Commonwealth Edison Company creates a st.bstantial safety hazard by authorizing operators at company nuclear plants to deviate from technical specifications and withdraw safety systems fecm operation by the company's VICE-PRESIDENT'S INSTPUCTION No.1-0-17 of March 1,1931. I notified Mr. Stello by letter dated July 2, 1981.

I wrote to Mr. Stello & seccrd tine. In a letter d6ted Noverbcr 17, 1981, I inforred Mr. Stello again that Comrwealth Edison Company creates a substantial safety hazard by authorizing operators to deviate from technical '

specifications and withdraw safety systems frem operation at Dresden Quad Cities and Zion stations.

The changes to Federal Regulations which permit a senior operator to depart from technical specifications when operating a corrercial nuclear pher plant in an enargency, becare effective June 1, 1983. In justifying the changes, you were told that er.ergencies can arise during which compliance with a license coridition or a technical specification could prevent necessary action to protect public health and safety. Public health and safety are protected frcm a comrercial nuclear pcwer plant's radiation by plint design, t

Plant design ensures the integrity cf physical barriers which prevent the uncontrolled release of radioactivity. Operating the nucleer plant within safe y limits ensures the integrity of these physical barriers. Compliance with technical specifications during an emergency requires an operator to (1) operatt with the reactor's automatic protective devices set to function to J correc : an abnormal plant condition before a safety limit is reached; (2) operat t with safety equipment ready to perform as designed to keep the plant within safety limits during an emergency.

emitting a nucle;r plant operator to deviate from technical specifica.

tionf risks exceeding a safety limit and betaching a barrier designed to prevent the uncontrolled release of radioactivity. To protect public health and safety from the uncontrolled release of radioactivity from a corrercial

Or. Nunzio J. Palladino Page 3 ,

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. nuclear power plant, direct nuclear plant operators to follow technical specifications; do not permit nuclear plant operators to deviate from tech;.1-cal specifications.

You were also told that the Special % .ew Group Office of Inspection and Enforcement en Lessons Learned from Three Mile Island, recommended the new rule. The Special Review Group wrote that actions such as releasing radioac-tive gas in greater concentration than permitted by technical specifications, might sometimes be justifiable. The Special Review Group recomended against giving blanket relief from technical specifications during an accident, however. The Special leview Group found that there would have been no acci-dent at the Three Mile Island if technical specifications had been followed.

Information on the Special Review Grour 's findings comes from paragraph 3.5 of NUREG-0616. l The General Prudential Rule for ships at sea is quoted as being similar to the new rule permitting a senior operator in a commercial nuclear power plant to depart from technical sper,ifications in an emergency. The Rules of the Road are rules for steering ships, rules for lookouts, lights, and other signals. The rules are designed to prevent ships from Colliding. The General Prudential Rule permits the captain of one ship to deviate from the rules if the capt61n of another ship is cauting drnger by violating the rules. A nucicar plant's technical specifications are different kinds of rules.

Technical specifications deal with :hysical principles. Technical specifica- <

tions are rules to ensure that operitors operate and maintain proper physical l conditions within the power plant. Operating and maintaining pecper physical conditions in the power plant--desi;n pcwer lev sis, Lerperatures, pressure, and reactor coolant systea ficas--e sures the ircegrity and safety of the nucler.c plant, ,

The General Prudential Rule applies to navigating ships at sea and in inland waters. The Rule does not apply to the operation of the nuclear power plant of a nuclear powered ship.

The Federal Aviation Administration rule,14 CFR 91.3, is quoted as being similar to the new rule. The Federal Aviation Administration rule permitt an aircraf t pilot to apply basic aerodynamic principles and deviate from a  !

Federal Aviation Administration rule when necessary to avoid endangering his r aircraft. For exarple, it wculd be wrong to require an aircraf t pilot to attempt to maintain assigned altituce when experiencing serious engine prob.

lems. A nuclear plant operator is applying basic physical principles when following technical specifications so he should not be permitted to deviate from these rules.

When an operator, operating a commercial nuclear pcwer plant, departs from technical specifications, he:

(1) operates the nuclear reactor with process variables--reactor power, reactor coolant flows, reactor coolant temperature, reactor coolant p essure--outside safety limits, or (2) turns off or changes the settings for the automatic protective devices designed to correct an abnormal plant condition before a safety limit is reached, or (3) turns off or shuts down equiprent required for the safe operation of ,

the nuclear reactor. [

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  • Dr. Nunzio J. Palladino Page 4
    • Technical sped fications are defined in the Code of Fe h ral Regulations, l, 1", CFR 50.36:

To protect public health and safety from the uncontrolled release of radioactivity from a commercial nuclear power plant, direct the licensee of a nuclear plant to manage the plant to operate in accordance with the plant's Operating License and Technical Specifications.

In my letter of May 3, 1984, I urced you to:

(1) Cancel the new Federal Regulations, which permit the license of a comercial nuclear power plant to deviate from tec:'.nical specifica-tions in an emergency 10 CFR 50.54 (x) and (y),

(2) Tell the president of General Public Utilities Nuclear Corporation that you expect him to promulgate policy that Three Mile Islaric Unit 1 is to be m crated in ar.cordance with the Operating License and Technical 5,9cifications, (3) Have Nuclear Regulating Cornission inspectors inspect Three Mile Island Unit 1 to ensure that the president of General Public Util-ities Nuclear forporation has implemented policy to operate Unit 1 in accordance with the Operating License and *echnical Specifica-tions.

(4) Have a Nuclear Regulatory Comission inspector inspect Three Mile Island Unit I daily to verify that the nuclear plant is being operated in accordance with the Oparating License and Technical Specifications. Have an inspector inspect daily and report results to the Regional Atinistrator.

This letter is written to reaffirm these recorcendations.

Sincerely yours,

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Charles Young Copy to:

Thomas M. Roberts, Commissioner U.S. Nuclear Reguletory Comission Washington, DC 20555 Victor Gilinsky, Comissioner U.S. Nuclear Regulatory Conniasion Washington, DC 20555 James K. Asseltine, Cominioner U.S. Nuclear Regulatory Comission Washington, DC 20555 Frederick Bernthal, Cornissioner U.S. Nucleer Regulatory Comisston Washington, DC 20555

262 Sheffield Lane Glen Ellyn, IL 60137 s July 17, 1984 Dr. Nunzio J. Falladino Chairman U. S. Nuclear Regulatory Comission Washington, D. C. 20555 l

Dear Mr. Chairman:

I hereby inform you that you have created a substantial safety hazard in the operation of commercial nu-lear power plants in the United States. You amended Federal Regulations for operating commercial nuclear power plants.

You now permit a senior operator operating a commercial nuclear pcwer plant to depart from plant Technical Specifications. You permit a senior operator operating a commercial nuclear power plant to withdraw a safety system from operation.

The Atomic Energy Commission did not permit cperators operating comercial nuclear power plants to withdraw a safety system from operation. An Operating License issued by the Atomic Energy Comission required a utility to oper6te the nuclear plant in accordance with plant Technical Specifications.

You have amended the Code of Federal Regulations, 10 CFR 50.57, by issuing new regulations 10 CFR 50.54 (x) and (y). Federal Regulation 10 CFR 50.57 requires the licensee of a comercial nucinr power plant to operate the plant in accordance with plant Technical Specifications. Federal Regulations 10 CFR 50.54 (x) and (y) relieve the licensee of this responsibility.

I have inforced authorities in the past that permitting an operator operating a comercial nuclear power plant to deviate from Technical Specifications and withdraw a safety system from operation creates a substantial safety hazard:

(1) I informed Mr. James J. O'Connor that Comonwealth Edison Conpany creates a substantial safety hazard operating nuclear power plants at Dresden, Quad Cities and Zion stations by permitting operators to with-draw a safety system from operation. I informed Mr. O'Connor by a Comonwealth Edison Company DEVIATION REPORT dated September 4,1980.

Mr. O'Connor is president of Commonwealth Edison Company.

(2) ! informed Mr. Victor Stello that Comonwealth Edison Company creates a substantial safety hazard operating nuclear power plants at Dresden Quad Cities and Zion stations by permitting cperators to with-draw a safety system from operation. I informed Mr. Stallo by letter dated July 2, 1981. Mr. Stello was Director, Office of Inspection and Enforcement, U. S. Nuclear Regulatory Comission.

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Dr. Nunzio J. Palladino July 17, 1984 Page Two (3) I informed Mr. Stello again that Convenwealth Edison Company creates a substantial safety hazard operating nuclear power plants at Dresden, Quad Cities and Zion stations by permitting operators to withdraw a safety system from operation. I informed Mr. Stello by letter dated November 17, 1981.

I am informing you that you create a substantial safety hazard by permitting operators operating commercial nuclear power plants in the United States to withdraw a safety system from operation. I am informing you in accordance with the Code of Federal Regulations, Part 21.

Sincerely yours,

) /t ,1.t . bj - s, Charles Young ,;)

cc: Mr. Thomas M. Roberts, Commissioner U. S. Nuclear Regulatory Connission Washington, D. C. 20555 ftr. James K. Asselstine, Cormissioner U. S. Nucicar Regulatory Cecmission l

Washington, D. C. 20555

! tir. Frederick Bernthal, Commissioner U. S. Nuclear Regulatory Commission Washington, D. C. 20555 i

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[d';. m j. .I'S NUCLEAR REGULATORY COMMISSION UNITED STATES 3 W ASHING TON, D. C. 20656

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Mr. Charles Young 262 Sheffield Lane Glen Ellyn. Illinois 60137

Dear Mr. Young:

Your June 14, 1984 letter to Chairtnan Palladino in which you commented on the regulation 10 CFR 50.54(x) and (y) which permits deviations from terh-nical specifications in an emergency, and asked that it be cancelled has been referred to me for reply.

I would like to emphasize that the rule cannot be invoked by a licensee et will. Specific circumstances must exist before the rule can be used and controls exist to prevent abus D hese are set out below:

1. An emergency situation must exist.
2. Licensee action must be reasonable.

3.- The actior, taken must be immediately needed to protect the public health and safety.

4 No action consistent with the license that can provide adequate or ecuivalent protection is immediately apparent.

5. Licensee most innediately notify NRC via the dedicated i

phone lines.

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6. The action mun be approved, as a minimum, by a licensed senior operator.

The rule makes it clear that the burden for safe operation and proper action that may be needed to protect the public health and safety in an emergency rests with the licensee. With this rule, a licensee cannot excuse itself from responsible action en the basis that the license prevented it.

On balance, we believe the rule is worthwhile and an improvement to safety and therefore should be retained.

Sincerely.

[ W Harold R. Denton, Director Office of Nuclear Reactor Regulation p H - c ri s ,i n A O_

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Glen Ellyn, IL 60137 August 6, 1984 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Comission Washington, DC 20555

Dear Mr. Denton:

In your July 31st letter, you write that the new Federal Regulation which permits a licencee to deviate from technical specifications when operating a nuc'. ear plant Nild be retained. The Three Mile Island Unit 2 operator deviated fror., nical specifications at 0403 the morning of Ma.ch 28, 1979.

The nuclear plant operator turned of f an emergency signal and shut down the emergency core cooling system.

You cite specific circumstances which nust exist before the licensee of a commercial nuclear power plant is to deviate from technical specifications.

An emergency existed at Three Mile Island the morning of March 28, 1979. An emergency existed and Three Mlle Island's licensed senior operator approved the action of the nuclear p' . ant opt.rator. The senior e,)erator thought that it was reasonable to turn off the emergency signal and shut denn the argency core cooling system because it was not immediately apparent to him that following technical specifications was providing protection. It was not ,

inrediately apparent to the senior operator that following technical specificatior.s was needed to protect the rablic health and safety. It ns not innediately apparent to him that fuel design limits might be exceeded threatenir.g a barrier designed to prevent the release of radioactive fission products and prote:t public health and safety. Fuel design limits were  ;

l exceeded. A barrier designcd to prevent the release of fission products was i l breeched thereby threatening the health and safety of the public.

l Region I of the Nuclear Regulatory Comission was notified about the accident [

' at 0845, March 28,1979. At 0845, reactor coolant system cressure was below i l the set point of the emergency core cooling system but the eurgency core l cooling system was shut down. The licensee continued to duiate from techni-cal specifications. Fuel design limits had been exceeded, fission products had been released and the health and safety of the public threatened.

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Mr. Harold R. Denton, Director August 6, 1984  ;

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If Three Mile Island's senior operator had followed the plant's technical specifications at 0403, March 28, 1979, there would have been no accident at Three Mile Island. The nuclear rcactor would not have been wrecked and the health and safety of the public eculd not have been threatened.

Your change to Federal Regulations permits a senior operator operating a commercial nucicar power plant to turn off an emergency signal and shut down a safety system. Serious accidents at: 'tkely at nuclear power plants if operators turn off emergency signals and shut down emergency systems. Serious accidents are likely at nuc' ar power plants if licensees deviate from techni-cal specifications as now pt :ted by Federal Regulations.

Again I t:;e you to cancel Federal Regulations 10 CFR 50.54 (x) and (y) and require licensees to follow terinical specifications when operating commercial nuclear power plants.

Sincerely yours,

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Charles Youn'g <I 1

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f[,.o Ts- esgk' UNITED $TATES NUCLEAR REGULATORY COMMISSION i 5 WASHINGTON, D. C POSM

  • 5 e....f AUG 2 31984 Mr. Charles Young 762 Sheffield Lane t Glen Ellyn, Illinois 60137

Dear Mr. Young:

Your letter of July 17, 1984 to Chairman Palladino regarding the regulation that permits deviations from technical specifications in an emergercy has been referred to me for reply, t The similarity of this letter to an earlier letter from you dated June 14, i i

1984 (also to Chainnan Palladino) suggests that you may not have ruefved my response to your earlier letter which was dated July 31, 1984. A copy [

of that response is enclosed which also servos as our response to your i recent July 17 letter. l Sincerely. .

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M' ' 7Har

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s. Denton,

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Director

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Office of Nuclear Reactor Regulation j

Enclosure:

NRC letter dated - l July 31,1984 j I

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