ML20206E043

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Expresses Concern Re Two Hazardous Practices at Ref Plants, Including Risking Meltdown by Authorizing Operators to Turn Off Nuclear Plant Safety Sys During Emergency
ML20206E043
Person / Time
Site: Dresden, Quad Cities, 05000000
Issue date: 01/29/1988
From: Cale Young
AFFILIATION NOT ASSIGNED
To:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20206D924 List:
References
NUDOCS 8811170374
Download: ML20206E043 (3)
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Text

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l 262 Sheffield Lane Glen Ellyn, IL 60137 January 29, 1988 r

Rogional Administrator, Region III .u,"", ,) J #.fu U.S. Nuclear Regulatory Commission p>4 v '

799 Roosevelt Road 60137 Olen Ellyn, Illinois Dear sitt I am writing to notify you of safety problems at Commonwealth Edison's nuclear power plants.

on May 12, 1987, I made a formal complaint to the Illinois i

l Commerce Commission. I cited two hazardous (1)practices employees at work  ;

' Commonwealth Edison nuclear power plants:

near a nuclear reactor producing power at Dresden and Quad cities stations; and (2) the Company risks a nuclear fuel J

meltdown by authorizing operators to turn off a nuclear plant ,

safety system during an emergency.

i During proceedings conducted by the Illinois Commerce l Commission, a lawyer for the company acknowledged that t

commonwealth Edison officials authorize workers to make repairs in a reactor drywell when the nuclear reactor is producing power at Dresden and Quad Cities Stations. Radiation lev I primary containment vessel - when the reactor is producing power. Worker's eyes are susceptible to damage by f ast j

neutron radiation from the operating reactor. Fast neutrons in the ,

i are not a hazard when the reactor is shut down. Work l primary containment is supposed to be done when the reactor 1 .

the reactor producing power, a safety function is lost and l l

there is a major reduction in the degree of protection ,

- provided public health and safety. Working in the primary ,

containment with the reactor producing power is therefore a [

substantial safety hazard.

The Operating Licenses for the nuclear plants at Dresden and

] Quad Cities prohibit work in the primary containment when the 2 Technical nuclear reaccor is producing power. Dresden Unit ,

specification 3.7.A.2, and Definition P, require that the i primary containment be closed and sealed when the reactor is 7

~ critical. Authorizing work in the primary containment with (.

the reactor producing power violates the Atomic Energy Act of '

i 1954.

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y c During the Commission proceedings, the Company lawyer also acknowledged that Commonwealth Edison officials authorire operators to turn off a safet.y system before the system has

" accomplished its design purpose. Operators are authorized to turn off water being pumped into a nuclear reactor by a safety system before the system has finished its $ob.

Operators are authorized to turn off a safety system if reactor coolant system pressures, temperatures, and levels are stable. With reactor coolant system pressure stable but low, temperature stable but high, and level stable but low, the reactor's nuclear fuel can be burning up. An operator following instructions issued by Company executives can cause  ;

the meltdown of a reactor's nuclear fuel.

When a safety system is turned off, a safety function is lost '

and there is a major reduction in the degree of protection provided public health and safety. Operators' therefore create a substantial safety hazard by turning off a safety system during an emergency before the system has finished its

$ob. '

l Commonwealth Edison officials acknowledge that there is a risk in allowing an operator to turn off a nuclear plant ,

, safety system before the system has finished its job. The risk is an accident like Three Mile Island. '

These officials say there is also a risk in not allowing an  ;

operator to turn off a safety sy. stem before the system has  !

finished its job. But officials db not explain this risk - '

the risk of allowing a safety syste.n to operate as designed i during an emergency in a nuclear power plant.

The operating Licenses for commonwealth Edison nuclear power plants require a safety system to pump water into the nuclear reactor as long as the abnornal condition which triggered the '

system to start, persists. Authorizing operators to turn off

, a nuclear plant safety system before the system has

, accomplished its design purpose violates the Atomic Energy Act of 1954.

I therefore notify you that Commonwealth Edison Company fails to comply with the Atomic Energy Act of 1954, and creates a  !

2 substantial safety hazard when operating nuclear power  :

plants. I notify you in accordance with the Energy Reorganization Act of 1974, section 206; and the code of Federal Regulations Parts 21.1, 21.2 and 21.21. '

Very respectfully, l

k M. 79 f Charles Young '

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-c ,',.

Ccpy to:

Mary 5, But,hnell, Chairman Illinois Commerce Commission Illinois ).partment of Nuclear Safety L0ndo tech, Chairman U.S. Nuclear Regulatory Commission e

3

.. t o s 262 sheffield Lane j h' -

Glen Ellyn, 11. 60137 V

July 7, 1988 y

Nr. Lando Zech /

Chairman U.S. Nuclear Regulatory Commission WJohington,' D.C. 20555 DOar Lando:

The nuclear industry has overlooked the'most important lesson from the Three Mile Island accident. A management official, a socior Operator, stationed in the control room would have A management recognized the loss of coolant accident.

of ficial in the control room responsible for operating the nuclear plant in accordance with the Operating License, would have prevented damage to the nuclear reactor.

B3 fore the accident, operators in the control room were operating three reactor coolant systens abnormally to ,

compensate for a leak. The reactor coolant system leak increased several hours before the reactor scram. After the roactor scram instruments and alarms in the control room cignaled a loss of coolant accident.

A management official in the control room would have recognized the reactor coolant system leak after the reactor scram. Being responsible for operating the i nucleardpower Technical plant in accordance with the Operating L cense an Specifications, this official would have ordered the primary plant operator to turn on the high pressure injection system.

The accident would have been terminated without damage to the nuclear reactor.

My I

Ifirst made two studies of the Three

- a study of the actions of operators during the first Mile Island accident.

few minutes of the accident - shows that the operators should have followed their rules for operating the nuclear plant.

If operators had followed plant precedures and Technical specifications as required by the Operating License, there would have been no accident.

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l My second study shows the errors of Three Mile Island l Cperators and managers and Metropolitan Edison executives, during the first day of the accident. On pages 37-40 of THE STUDY, errors of the first management official to arrive on Ocene - the Superintendent Technical Support - are' identified. Corrective action for these errors - stationing a management of ficial, a qualified O'nior Operator, in the ,

ccntrol room in charge - is proved n pages 42, 43, and 44. '

Carrective action is summarized on pages 15 and 16 of the

SUMMARY

Enclosed are copies of my two studies of the Three Mile Island accident.

Sincerely yours,

,5 7

3 U

4]

p Charles Young Enclosures l

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