ML20072C581

Testimony of C Reed on Contention 1 Re Util Inability or Unwillingness to Operate Facility within NRC Regulations. Related Correspondence

ML20072C581
Person / Time
Site:	Byron
Issue date:	03/01/1983
From:	Reed C COMMONWEALTH EDISON CO.
To:
References
ISSUANCES-OL, NUDOCS 8303080482
Download: ML20072C581 (11)

Text

COMMONWEALTil EDISON COMPANY N

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g Date: March 1, 1983 p UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

\m BEFORE TIIE ATOMIC SAFETY AND '~

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(Byron Nuclear Power Station, ) -

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SUMMARY

OF CORDELL REED'S TESTIMONY ON CONTENTION 1 Cordell Reed is Commonwealth Edison Company's Vice President of Nuclear Operations. As such, he is responsible for the operation of all of Edison's nuclear power plants, including the Byron Station. Mr. Reed's testimony describes both his and Commonwealth Edison Company's strong commitment to the safe operation of those plants.

This committment is reflected through Edison's continuing support of industry-wide efforts to enhance nuclear safety and specific activities at the corporate level and at Byron Station. Edison's strong commitment also is explained to its operating personnel who are expected tc share in and carry out this commitmenc.

Because of this commitment to nuclear safety, Mr. Reed concludes that past incidences of non-compliance by Ediscn do not indicate an unwillingness or inability of 0303080482 830301 DRADOCK05000g

Edison to conform with NRC standards. Edison has evaluated all such instances of non-compliance and has taken corrective action. Edison has a great deal of experience in operating nuclear power plants and is now more able to comply with NRC regulations than at any time in its past.

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. 4 TESTIMONY OF CORDELL REED ON CONTENTION 1 Q.l. State your name and present occupation.

A.l. My name is Cordell Reed. I am the Vice President of Nuclear Operations for Commonwealth Edison Company.

I am the corporate officer responsible for the oper-ation of the Company's nuclear power plants, including the Byron Station when it becomes operational. I am also responsible for station nuclear engineering, nuclear fuel services and nuclear licensing activities of the Company.

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Q.2. Briefly state your educational and professional qualifications.

A.2. My qualifications are briefly summarized in Ex-hibit 1 to this testimony.

Q.3. What is the purpose of your testimony?

A.3. My testimony is intended to address, in part, Contention 1. That contention asserts that Commonwealth Edison Company lacks the ability or willingness to operate the Byron Station within NRC regulations. Ad-ditional prepared direct testimony will be submitted by the Company in connection with this contention. One is from Robert E. Querio, the Station Superintendent for

7 the Byron Station. He describes the structure of the Station management and the experience and qualifica-l tions of the personnel who will be directly responsible for the day-to-day operations at the Byron Station. He also describes the steps which have been and will be taken at the Byron Station to prevent recurrence of incidents of non-compliance with NRC regulations which have occurred from time to time at the Company's operat-ing stations.

Mr. Louis O. Del George, Staff Assistant to the Assistant Vice President for Nuclear Engineering, Nuclear Fuel Services and Nuclear Licensing, will describe the off-site organization to support the Byron w Station and the qualifications of the Company generally to operate safely the Byron Station. He will also discuss the past incidents of non-compliance with NRC-regulations.

Mr. Walter J. Shewski, the Company's Manager of Quality Assurance, will describe the Company's quality assurance program and the commitment of the Manager of Quality Assurance and his organization to the safe operation of the Byron Station. Mr. Shewski and Mr.

Michael Stanish, the Byron Station Quality Assurance Superintendent, also will discuss the disposition of certain items of non-compliance with NRC regulations which occurred during the construction of Byron Station.

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Mr. Querio, the Station-Superintendent for the Byron Station, reports to me functionally. Mr. Del George, Staff Assistant to the Assistant Vice President, reports directly to me. I, in turn, report to Mr. Eide Thomas, an Executive Vice President of the Company, and i

through Mr. Thomas to Mr. James O'Connor, the. Chairman and President of the Company. Mr. Shewski, our Manager of Quality Assurance, does not report through me, but rather reports to Vice Chairman Behnke, so as to assure the separation of quality assurance functions from responsibility for the operation of the Station. Mr.

Stanish reports to Mr. Jhewski.

My testimony is limited to expressing the strong '

commitment of Commonwealth Edison Company to the safe operation of the Byron Station so as to protect the public health and safety, and the Company's commitment to operate the Byron Station within NRC and other requirements.

Q.4. Please describe the commitment of Commonwealth

. Edison Company to the safe operation of the Byron

( Station.

A.4. As the Corporate Vice President of Commonwealth Edison Company responsible for the operation of the r.

nuclear power plants, including the Byron Station, I am personally absolutely committed to the safe operatica of these plants. In this regard, I reflect the official

policy and the attitude of the upper management of Commonwealth Edison Company. That policy is expressed in a corporate order which I issued and is attached to my testimony as Reed Exhibit 2. The Company's strong commitment to the safety of nuclear power operations is reflected in its continuing support to industr.y-wide efforts to enhance nuclear safety, as well as the Company-wide and Byron Station specific activities described in the testimony of other witnesses.

Edison has always taken an active role in industry groups formed to address new or on going safety concerns, including support for the activities of the Atomic Industrial Forum and the Edison Electric Institute. '

The Company participates in a number of ad hoc groups formed to address specific technical safety issues, and contributes money and the advice of experienced company personnel to safety-related research conducted by the Electric Power Research Institute. We currently have approximately eight senior people involved in such ac-tivities.

Senior officers of Commonwealth Edison Company have recently been instrumental in the formation of industry-wide groups which enhance nuclear safety. Mr.

Thomas Ayers, our retired Chairman and President, to-gether with our current Chairman and President, James S. O'Connor, and Executive Vice-President Byron Lee, Jr., were active in the creation of the Nuclear Safety

a Analysis Center (NSAC) and the Institute for Nuclear Power Operations (INPO). NSAC was formed to review and report on accidents at nuclear generating stations and continues to review nuclear operating experience from the broad perspective of long-term safety. The first Chairman of the Research Advisory Group to NSAC was the Company's now' retired Vice-President of Engineering and he has since been replaced by Executive Vice-President Lee. INPO establishes best operating practices with regard to nuclear safety in overall plant operation and evaluates plants according to these criteria. INPO also evaluates reports of operating incidents at all nuclear power plants and, where appropriate, provides x power plant operators with advance warning of potential problems.

As part of my responsibility to insure the safe operating of our own nuclear stations, I feel it is important to convey to our operational personnel the Company's strong commitment to safety. As part of this commitment, the Company employs people who are tech-nically qualified for the positions in which they are i

placed and have a demonstrated ability to perform their job functions. These people are expected to share and i

carry out the Company's commitment to the safe oper-ations of its nuclear power plants. This commitment l

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also extends to the conformance to regulations of the NRC and other regulations which apply to the operations i

of our stations.

Q.5. Does the fact that Commonwealth Edison Company has been cited by the Nuclear Regulatory Commission and its predecessor, the Atomic Energy Commission, for non-compliance with regulations demonstrate an unwill-ingness or inability of the Company to conform to the standards set by the NRC?

A.S. No, it does not. As I stated above, the Company is dedicated to the safe operations of its stations, including compliance with all applicable regulations. .

When instances of non-compliance have been observed in the past, the Company has evaluated the incident and has taken action to correct any problems that may have been uncovered. We have learned a great deal from our many years experience operating nuclear power plants and through a rigorous process of self-analysis in areas where we may have shown potential weakness. As a result of this process, I believe that the Company is more able now than it has been at any other time in the past to comply with NRC regulatory requirements, and I expect the Company's performance to continue to improve in the future.

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' REED

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CORDELL REED Exhibit 1 .

Vica-Precident Commonwsaltn Edison Company

/ Chicago, Illinois

(,. Education Product of the Chicago Public School System. Bachelor of Science Degree in Mechanical Engineering from the University of Illinois in June, 1960.

Experience December, 1979 - Present Vice-President Responsible for all of the Company's nuclear activities including the operation of four duclear stations, the Nuclear Engineering Department, as well as nuclear licensing and nuclear fuel activities.

December, 1977 - December, 1979 Assistant Vice-President for Nuclear Licensing, Nuclear Fuel Services, and Environmental Affairs Departments.

March, 1975 - December, 1977 Station Nuclear Engineering Department Manager.

July, 1960 - March, 1975 Started working at Edison in 1960.

Assignments included coal-fired and

( .); nuclear power plants' design 'an'd "

operation.

Professional Activities Member of American Nuclear Society Member of Western Society of Engineers Member of NaLinnal Technical Association Member of Economic Club of Chicago Member of American Association of Blacks in Energy Registered Professional Engineer, State of Illinois, since 1965 Civic Activities President, Board of Truste'es, Abraha Lincoln Centre Trustee, Metropolitan Community Church Director, Illinois Junior Engineering Technical Society

. Business Activities Director, Independence Bank of Chicago Director, Project Management Corporation Argonne National Laboratory - Center for Educational Affairs Advisory Committee Illinois Institute of Technology - Board of Overseers - Armour College of Engineering g University L

of Illinois - Mechnical Engineering - Industrial Engineering Departmental Alumni Board University of Illinois - College of Engineering - Research and Development Industrial Advisory Board Northwestern University - College of Arts and Sciences Visiting Committee g -w - - - - - - - ,-#-

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, VICE-PRESIDENT'S INSTRUCTION NO.1-0-17 EXHIBIT 2

SUBJECT:

Company Policy Regarding Safe

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Operations and Adherence to Nuclear Procedures and Technical Specifications Effective: March 1, 1981 Cancels: V.P. Instn 1-0-17 (10-22-79)

This Instruction reaffirms 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 pdblic as well as station personnel. All personnel within the Company share this responsibility. In particular, it is the primdry 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 procedures and operating orders. Systems which could affect the public health and safety (including emergency core cooling system, rad-waste, etc.) are to remain in the operating mode as prescribed in the technical specifications.

It is recognized that circumstances may arise which were not foreseen in the preparation of technical rpecifications. For example, a combination of events which were analyzed individually may, taken together, produce results which were not expected or analyzed during reviews leading to the technieni 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 enly when necessary to solve an urgent problem and only after caraful consideration and approval by the Station Shift Engineer or, if there is insufficient time to contact him, the licensed Senior Reactor Operator immediately available in order to prevent (1) potential injury to the public or Company personnel, (2) potential releases off-site above technical specification limits, or (3) damage to equipment.

Further, it may be necessary upon occasion to temporarily withdraw a system from operation by placing it in a manual or pull-to-lock mode. This should be done only when conditions are " stable and under control", or when it is apparent that continued operation would aggravate or worsen the plant condition. In all instances such action should be taken only after careful consideration, and it must .

be reviewed and approved by the licensed Senior Reactor Operator immediately available. It is net expected that such operations will be conducted for prolonged periods.

Whenever a system is withdrawn from operation as outlined, continuing j surveillance of the relevant parameters must be maintained by a licensed Reactor Operator to assure the safe operation of the plant until the system can be restored to its normal operating mode or until it is no longer needed, es prescribed by the

! technical specifications. The conditions 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, and (2) if there is adequate core cooling as indicated by l

stable reactor coolant system pressures, temperatures and levels.

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,,l3-1-81)

VICE-PRESIDENT'S INSTRUCTION NO. 1-0-17 h 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 imediately.

. The Shift Technical Advisor / Station Control Room Engineer -

shall be consulted to determine whether imediate shutddwn or orderly power reduction.is appropriate.

. The Station Superintendent or his designate shall be notified who in turn should notify the Nuclear Duty Officer.

. The NRC shall be notified (if appropriate). ,

. A report shall be promptly made to the Division Vice-President of Nuclear Stations.

. A plant shutdown, imediate or by power reduction, shall be comenced 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 Superintendent or his designate may authorize prolonged operation if appropriate.

All station management shall be informed of this policy and it shall be

' included in our training program.

Pn-Vice-President

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