ML20206E086
| ML20206E086 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island, 05000000 |
| Issue date: | 09/28/1988 |
| From: | Beeson J NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| To: | Treby S, Vietticook A NRC COMMISSION (OCM), NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| Shared Package | |
| ML20206D924 | List: |
| References | |
| RULE-PRM-50-50 NUDOCS 8811170393 | |
| Download: ML20206E086 (8) | |
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- gnmeeg%, UNITED STATES E a NUCLEAR REGULATORY COMMISSION n a wAsMNG TON, D. C. 2C066 SEP 2 81988
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HEMORANDUM FOR: Annet.te L. Vietti-Cook Technical Assistant to Chairman Zech Office of the Chairman Stuart A. Treby Assistant General Counsel for Rulemaking and Fuel Cycle Office of the General Counsel FROM: Juanita F. Beeson, Chief Rules Review and Editorial Section Regulatory Publications Branch Division of Freedom of Information and Fublice.tions Services Office of Administration and Resources Management i
SUBJECT:
NOTICE OF RECEIPT FOR PRM-50-50 On September 26,1988, I sp.4e with pet 6tiener Charles Young by telephone about clarifying the notice of receipt for PRM-50-50 (08-26-88; 53 FR 32624) to accurately reflect the intent of his petition.
I read several times the proposed text and portions of the existing text under "11. Grounds for the Peution." The ccnversation proved fruitful because he wanted the first two sentences under this heading removed so that the grounds discussed related only to Three Mile Island, Unit 2, and 10 CFR 50.54(x) and (y).
He agreed that the proposed notice as revised with him during the telephone conversation accurately c(.tracterized his petition.
Af ter our initial conversation, Mr. Young called me to ask that I send him a
! copy of the revised notice. I plan to send him a copy of the enclosed notice of clarification after it is published in the Federal Register unless you think that Mr. Young should review a draft of this notice before it is published.
i ! would appreciate receiving your verbal concurrence with publishing this
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notice at your earliest convenience.
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Q.o .gt J, Wuw Juanita F. Beeson, Chief a ,cy o ~ :~9 Rules Review and Editorial Section Regulatory Publications Branch Division of Freedom of Inform.ttion and Publications Services eati170393 001109 10 ADOCK 0500 g Office of Administration and Resources PDR H Management
Enclosure:
As stated
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NUCLF.AR REGULATORY COMMISSION 10 CFR Part 50
[DocketNo.PRM-5C-50]
Charles Young; Filing of Petition for Rulemaking AGENCY: Nuclear Regulatory Comission.
ACTION: Receipt of Petition for Rulemaking; correction.
SUWARY: This document clarifies a portion of the notice of receipt for a petition for rulemaking filed by Charles Young and docketed as PRM-50-50.
The notice of receipt for this petition was published August 26, 1988 (53FR32624). This notice provides additional information in support of the petitioner's original intent.
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FOR FURTHER INFORMATION CONTACT:
John D. Philips, Acting Chief, Regulatory Publicottons Branch, Division of Freedom of Information and Publications Services, Office of Administration and Resources Management, U. S. Nuclear Regulatory Comission, Washington, DC 20555, J
Telephone: 301-492-3783.
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2 In the notice of receipt for PRM-50-50 published on August 26,1988(53FR32624), ,
under the heading, "II Grounds for the Petition," remove the first two sentences and insert the following sentences in their place:
The petitioner states that not following technical specifications in an emergency -
J could lead to an accident similar to the one at Three Mile Island, Unit 2.
l The petitioner states that Federal Regulations require a nuclear plant safety system to pump water into a nuclear reactor as long as the abnormal condition ,
i which activated the system persists; but, that Connonwealth Edison's Policy I
permits operators to turn off water being pumped into a nuclasr reactor during an emergency before the safety system has finished its job. The petitioner ,
notes that turning off water being pumped into a nuclear reactor during an a
emergency can cause a nur. lear fuel meltdown, release of highly radioactive fission products, and exposure of plant personnel and people nearby to ;
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- hazardous radiation. The petitioner offers that during a Proceeding before !
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i the Illinois Comerce Comission on September 15, 1987, Connonwealth Edison's
- attorney cited 10 CFR 50.54, paragraphs (x) and (y) as authority for their
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policy. The petitioner states that this policy applies to all of Commonwealth Edison's nuclear power plants; therefore, the petitioner concludes that ,
Commonwealth Edison risks an accident such as the accident at Three Mile Island Unit 2 at twelve nuclear power plants.
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Dated at Rockville, Maryland, this ........-.. day of ------..-.-. 1988. [
i Samuel J. Chilk, Secretary of the Commission, j L
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Glen Ellyn, II. 60137 g.
September 3, 1988 Nr. Max J. Clausen
(;i Senior Technical Assistant to Chairman Zech ;
U.S. Nucleak Regulatory Commission YN.
Washington, DwC. 20555
Dear Mr. Clausen:
I appreciate your sending me a copy of the petition which requests that the NRC rescind paragraphs (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, nexu to last paragraph). It is this Policy that can lead to an accident like Three Mile Island.
Commonwealth Edison's Policy for operating nuc1 Jar 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.
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Duting proceedings before 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 C3 Cnc1Coing a ccpy of cy FCbruary 24, 1988, lottor to Mr.
Call, Investigation and compliance specialist, in Region III.
This letter contains a copy of Commonwealth Edison's defective policy.
Thanks again for your letter. .
Sincerely yours, El + j m Charles Young Enclosure l
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'/ 262 Sheffield Lane Glen Ellyn, IL 60137 February 24, 1986 Mr. Charles H. Well Investigation and compliance Specialist U.S., Nuclear Regulatory Commission, Region III Post Office Box 2027 Glen Ellyn, Illinois 60138-2027
Dear Mr. Weil:
My letter of January 29, 1988, describes two safety problems at Commonwealth Edison auclear 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' safety system, can occur at any Commonwealth Edison nuclear power plant.
The Energy Reorgan\zation Act of 1974, places respotesibility for safety on officers of companies operating nuclear power plants. Section 206 of the Act reads that an officer of a firm operating e 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 author.i tes 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 i
low, temperature stable but high, and level stable but low, the reactor's nuclear fuel can bt burning up.
s An operator at any commonwealth Edison nuclear power plant l' can cause serious damage by following instructions issued by ,
i 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 i nuclear fuel.
A copy of the defective Policy is enclosed. I have underlined one of the defects in the Policy.
Very respectfully, bl ul- 91 Charles Young Enclosure D C' i th // / th n r
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Copy to:
Mary B. Bushnell, Chairman Illinois Commerce Cotm!ssion
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Illinois Department of Nuclear Safety Lando Zech, Chairman U.S. Nuclear Regulatory Commission i
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, [ ] Commonwealth Edken Company
,o O VICE FRESIDETT'S INSTRUCTION MO.1-0-17
SUBJECT:
Company Fol'ry Regarding Safe k Operations and Adherence *,o
( Nuclear Procedures and Technical Specifications Effectiver August 18, 1986 Cancels: V.F. Instn 1-0-17 (5-23-83)
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This Instruction reaffirms Company policy regarding adherence to nuclear procedures and technical specifications.
The primaty 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 wellInas station personnel. All personnel within the Company share this responsibility.
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 safety goal, plant operation is to be within the boundaries specified in our technical specifications and in adherence to proceitures and operating orders. Systems which could affect the public health and safety (including energency core cooling system, rad-vaste, etc.) are to remain operable as prescribed in the technical specifications.
It is recognized that circumstances may arise which were not foreseen in the preparation of technical specifications. yor example, a combination of events which were analyzed individually say, taken together, produce results which were not In these
( expected or analyzed during reviews leading to the technical specifications.
rare, unforeseen circumstances literal adhe:ence to the technical specifications may cause, rather than prevent, problems. If such circumstances should arise, prudence may require operation outside of the technical specifications. Trocedures, or sperating orders. This should be done only when necessary to :olve an immediate problem and only after careful consideration and approval by the Station ShifC E ;neer or, if there is insufficient time to contact him, the licensed Senior Reactor Operator immediately available in orda- to prevent (1) injury to the public or Company personnel (2) releares off-sits 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 inrsediately apparent which can provide adequate or equivalent protection.
Further, it any be_necesserv upon occasj.on to temeerariiv vithdraw a syg,Lgg or systems fres operation by placini it in a manual or Dull-to-lock mode. This should be done only when conditions are "stable _and under control". or when it f.sThe apparent confill.g.c3 that continued operatt a would aggravate or vorsen the plant condition.
pf "stable and under control" are considered to exist (1) if the radiation levels and the pressure and temperature in the primary containment are stable, and (2) if there is adequate core cooling as indicated by stable reactor coolant system pressures.
tempsratures and levels. In all instances such action should be taken only after
( careful consideration, and it must be reviewed and approved by the licensed Senior Reactor Operwtor immediately available.
It is not expected that such operations vill be conducted for prolonged periods.
(
Ill. C. C. Docket 87-0228 Exhibit A
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! .. 2 ' - VICE PRESIDENT'S INSTRUCTION MO.1*0-17 '
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Whenever a systen is withdrawn from operation as outlined, continuing surveillance of the relevant pcrameters must be maintained by a licensed Reactor operator ta assure the safe operation of the plant until the system can be restored .
t3 aormal operability or until it is no longer needed, as prescribed by the b
t:chnical specifications.
In all cases noted above, when the technical specification boundaries are exceeded or when a system is withdrawn from operation:
. The Station Shift Engineer shall be 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 appropriata.
. The Station Manager or his designate shall be notified who in turn shall notify the Nuclear Duty Officer in accordance with established procedures.
. The NdC Operations Center shall bt notified by telephone. When time permits, the notification aust be made tefore the protective i action is'taken otherwise, the notification must be made as soon as possible thereafter.
. A report shall be promptly made to the Division Vice Presideut -
Nuclear Stations.
. A plant shutdown, immediate or by power reduction, shall be commenced unless prolonged operation under the circumstances is concurred in by the NAC in the case of operating outside the !
technical specifications. In other cas8s the Station Manager or his designate ray authorize prolonged operation if appropriate.
I All station personnel shall be informed of this policy and it shall be 1:cluded in our training program. ,
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Vice President ,
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0 32824 Federal Registee / Vol. 83. No 166 / Friday, August 26, 1988 / Proposed Rules NUCLEAR REGULATORY COMMISSION 10 CFR Part G0 (Doceet No. PflM-50-601 Chartes Young: Fiting of Petloon for Rulemaking Aoswcy: Nuclear Regulatory Commission.
ACTiow: Notice of receipt of petition for rulemsking. I Sunene Amr. The Commisslon is pubbshing for public comment this notice of receipt of a petitio.a for rulemaking dated April ta.1944, which was filed with the Commisalon by Charles Young. The
. petitu>n was docketed by the Commission on July 3.1984, and has been assigned Decket No. PRM-m-50. !
The petitioner requests the Commission to amend its regulations to rescind the i pr) vision that authorizes nuclear power r p' ant operators to dettata frora technical specifications during an emergency.
DAts: Submit ecaments by October 25.
( 1944 Comments recehed after this date will be considered if 11 is ptsctical to do no, bet assurance of considerstion csnnot be El ven etrept as to comments received on or before this date.
Fed::ral Ecgistzt / Vol. 53, No.106 / Friday Aug'ist 26,'1988 / Proposed Rules 32625 ADDRESSES: Submit comments to: prevented il p.4nt operators had nuclear power plant shall establish Secretary, U S. Nuclear Regulatory followed the requirements of the plant's policy for operating the plant. The Chief Commission. Washington. DC 20555. operating license and technical Executive Officer shall direct that the Attentiom Docketing and Service specincations. According to the nue; ear power plant be operated in Branch. For a copy of the petition, write: petitioner, the three investigations add accordance with the Operating Licente Rules Re.lew and Editorial Section, their applicable findings are as follows: and Technical Speci0 cations.
Regulatory Publications Branch. (1) The President's Commission found Dated at Rociatlle. MD this 22nd day of Disision of Freedom ofInformation and that reactor core damage would have August of 19as.
Publications Services. Office of been prevented if the high pressure For the Nur! car Regniatory Commission.
Administration and Resources inje tion system had not been throttled.
\tanagement. U.S. Nudear Regulatory (Keny Commission Finding 84, pg 28) 8 ***'I N' Commission. Washington, DC 20555. Gl Calculations by the Special Inquiry Secretory of 'he Commission.
Group show that use of he high [Dt Doc. 9a. ,9428 Aled G-25-a8. 8 43 amj FOR FURTHER INFORM ATION CONTACT.
pressure injection system would have eussecoes sows-as luanita Beeson Editorial Chiet'.tory Section. Regula Rules Review ant *, prevented overheating of the fuel and Publications Branch. Daision of release of radioactive material.
' (Rogovin. Vol ll. Part 2, pgh Dib. pgs Freedom ofinforms tion and Publications Sersices. Office of 558,561)
Administration and Renurces (3) The SpecialInvestigation b) the hianagement. Washington, DC 20555. Senate Subcommittee on Nuclear Telephone (301) 492-8920. Regulation found the cause of severe SUPPLt ut NT ARY INFOMMATIC N:
damage to the te tctor core was the inappropriate overriding of automatic Dsckground safety equipment by plant operators and
/. rrtitioner's /nterest managers. (Itart Report Chapter 2, Findings and Conclusions. #2 pg 9)
Kit. Charles Young, the petitioner, is The petitioner believes the NRC requesting th . NRC to rescind should rescind the esisting provisions in paragraphs (s) and [y) of 150.54 of 10 paragraphs (x) and (y) of i 50.54 to CFR. The regulation, issued on June 1, adequately protect the public health and i 1983 (48 FR 13906). authorizes a senior safety from the hatards of nuclear operator in a nuclear power lant to radiation when nuclear energy is deviate from technical speem} cations producing in power, an emergency. The petitioner opposes the regulaticn because he belieses that 111. Petitioner's Proposa!
nuclear powel plants should be ope.ated in accordanca with the PART 50-( AMENDED) j operating license and appt >priate The petitioner proposes that to CFR
- technical specifications and that 5a54 (x) and (y) be amended to read as
, requiring a senict operator to follow the fo!!ows:
1 technical specifications during an emergency enhances plant safety, 9 SdH Conews of Ucenses.
, The petitioner notes that technical (x)The Atomic Energy Act of1SH
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specifications lo) prescribe settings for f safety systems at nuclear power plants, stipulates that a licensee shall operate a 4 such as the emergency core coolms commercial nuclear power plant in j system, so that action of a safety system accordance with technical will correct an abnormal condition s pecifica tions. Technical s pecifica tions i befora fuel design limits are esceeded: define the specific characteristics of a ,
l and (b) require an automatic safety nudear power plant which ensure that !
l system to operate as long as the fuel design limits att not etceeded j abnormal condition which threatens the during normal operations and a nuclear fuel esists in the plant. emergencies. Dy review of a nuclear power plant's safety analysis and i
/!. Creuds for the Feh.tio^ technical specifications, the Nuclear i The petitioner cites seseral cases of Regulatory Commission determines that ,
! harardous practices where, the utilisation of special nuclear material l petitioner asserts, the licensee has will be In accord with the common L i giohted Federal regulations at the defense and security and will provide 1 Dresden and Quad Cities Nuclear Pow er protection to the health and safety of the j i Plants, owned by Commonwealth publir To r "ent fuel damage and j Edison Company. Chi aso, !!1 nois. The protect publis health and safety from the I p>titioner beltwes that these practices hasards of nuclear radiation, a licensee could lead to en accident simdar to the shall follow technical specincations i one at Three hide liland, Unit 2. The when operating a commercial nuclear j petilloner claims that three offict&l pow er plant. -
i insestigations hase confirmed that (y)The Chief Executhe Officer of a }
- damare to the nuclear reactor at Three public utility or other organlastion hide Island. t' nit 2. could hav e been licensed to operate a commercial f
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Federal Resister / Vol. 53 No.187 / hionday August 29, 1988 / Proposed Rules 32913 10 CFR Parts 2 and 50 to reinstate financial qualfications as a consideration in the operaHng If cens!ng nearing far electric utilities. ,
oats: Submit comments by October 28, 1988. Comments received after this date will considered if it is practical to do so, but assurance of considerstbn cannot be given except as to comments received on or before this date.
Aoomassea: Submit comments to:
Sectetary U.S. Nuclear Regulatory Commission, Wsahington DC,20555.
Attention: Docketing and Settice Branch.
For copies of the petition for rulemaking, write: Reles Review and Editorial Section, Regulatory Publications Branch. Division of Freedom of Information and '
Publications Services. Office of Administration and Resources Management, Nuclear Regulatory Commission, Washington DC,20555.
F04 FUsrrHER 88eFOnesATION CONT ACf:
Juanita Beeson, Chief, Rules Review and Editorial Section, Regulatory Publicatiorw Branch, Division of Freedom ofInformation and Publications Sertices, Oftce of Administration and Resources ^
Managemera, Nuc' ear Regulatory Commission. Washington DC,26,45 Telephone (301) 492-4928.
SuePLasseprTARY teeF04se Attoic . i
Background
The Commission publis,hed a final rule on September 12,1964 (49 R 35747) thet eliminated financial qualifications from consideration drring the operating license review and hearings for electric utilities.The petitioner states that lasuance of this final rule prevents the
- ~ ~ financial condittor.of a utdity from bei g investigated during licensing NUCLEAR REGULATORY hearings, that the "' ' ' nde requires COMMISSM the assumption of financial adequacy 10 CFR Parts 2 and 50 * * * " which has resulted in several problems that could pose 6 danger to the (Dochet Ho. PMee-5&l21 public health arid safety.
Marwin Lowla; Petition for Rulemaking Petitioner's Interest Acancy:Nuclerr Regulatory The petitioner, Marvin I. Lewis, is a Commission. reisident of Philadelphia, Pennsylvania.
ACTiOw: Notice af receipt of petition for and is concerned about ti.e fUancial rulemakieg.
stability of the Philadelphla Electnc Company (PECO). PECO is the parent sussasARY:The Nuclear Regulatory utility for Limerick and Peach Bottom Commission is publishing for public nuclear power plants located in comment this notice of exelpt of a Pennsylvania. Mr. Ltwie belieses that petition for rulemaking dated June 6. Umenck 2 may go cridcal and 1988, that was submitted by Marvin L egentually have to shutdown and that Lewis. The petition was docketed on he and residents of the surrounding cea June 8.1988, and assigned Docket No. will be adversely affected by the PRM-50-52.The petition requests that shutdown. In addition to bemg espou d the Commission amend its regulations in to radiation from the radioactis e wme i
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32Mi - . Federal Register / Vol. 53 No.167 / Monday. August 29, 1988 / Proposed Rules produced by Umerick 2. Mr. Lewis is The petiti: net requests th6t NRC also concerned about the many costs Petitioner's Proposal reinstate financia! qualifications as a i associated with health risks. rate hies. requirement fw e! ctric utilities and e nd other unknown potential problems. PART 2-[AA4ENOtO] v suspend the licensing proceedings for '
Umerick 2 until t's parent utility, PECO' The petitioner requests that Part 2 be GM fw b Mon amended to revise il 1.4(s). 2.104(c)(41.
can demonstrate to the NRC that it is Mr. fewis cites severallong-stand:ng financially qualified to safely proceed ,
and paragraph VIL(b)(4)of Ak pendia A operating problems at Un.erick 1 and 2 with Umerick A and its other nuclear to renect the language prior to issuance end Peach Bottoro plants that he claims operations. The petitioner requests that of the final rule published September 12. ,
have placed a financial burden on the so-day commert period for this 1964 (49 FR 33747).
PECO. Mr. Lewis asserts that PECO has petition tw reduced in order to prevent admitted to being under financial further financ al hardship on PECO. PART $0-(AlittNDED) pressure and that the cast of Umerick 1 The petitioner requests that Pari 50 be cnd 2 has placed the company billions Condual*" I amended to revise il 50.2(s). 50.33(fl. I of dollare in debt. Mr. Lewis indicates Mr. Lewis believes that Umerick 2 is 50.40(b). and 50.57(a)(4) to reflect the I th:t the financial problems facing PECO going "critical " 1.e.. will begin to language prior to issuance of the final willlead to a situation such as the generate power, and may be closed. rule published September 12.1964 (49 F1t chutdown of Shoreharn nuclear power Even if the plant stays open. Mr. Lewis plint after it became radioactive. Mr. 35767).
states that the shipment of redinactive Dated at Rockvale MD this 23d day of Lewis states that Shoreham was granted wars will expose him to radiat!rsn a license despite the shaky financial without corresponding benefit, which he Assst teu condition of the pareut utility,long For the Nuclear Regulatory Commissiort claims is in violation of the Atomic Island ughting Company (ULCO). He Energy Act. Mr. L4wis states this Act Samuel l' Chilk.
clelins that ULCO has admitted that it exhorts the Fedeial Govemment to *"7 O' D'"*#"'"
does not have sufficient monies to pay 'pec:ect health and safety of the public (m wtW2 Filed s-26-44. 4 45 aml j for decommissioning of the nuclear a m ie coca n webe
' and that the Nuclear Regulatory power plant. Commission has been charged with G:neral Solution to the Prouem entweirg this maridate.
- Notice 2egading Petitioner's Request to Reduce 30<!ay Comment Period The staff has read the petitioner's letter to waive the 30 day comment penod for this notice of petition for rulemaking and determined that it la 4 - impractical to do so, therefore we are publishing this notice of receipt of the i petition for rulemaking with en 1
epportunity for the public to comment.
2 UNITED STATES
) NUCLEAR REGULATORY COMMISSION ""'"
WASHINGTON, D.C. 20555 ""u'sW ' "
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