ML20206E036

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Opines That 10CFR50.54(x) & (Y) Superfluous & Dangerous.Nrc Should Instruct Operators Not to Depart from Tech Specs in Emergency.Author Resume Detailing Experience in Commercial Nuclear Power Field Encl
ML20206E036
Person / Time
Site: Three Mile Island, 05000000
Issue date: 04/29/1988
From: Cale Young
AFFILIATION NOT ASSIGNED
To: Zech L
NRC COMMISSION (OCM)
Shared Package
ML20206D924 List:
References
NUDOCS 8811170369
Download: ML20206E036 (4)


Text

F. ,

262 Sheffield Lane "~

s" Glen Ellyn, II. 60137 -

April 29, 1988 '

s .

Mr. Lando Zeca ..

Chairman U.S.Huclear Regulatory Commission Washington, D.C. 20555

Dear Lando:

After leaving the Navy in 1972, I came to the Chicago area to work foi the Atomic 1:nergy Commissica. For two yeers !

inspecte0 nuclear plants under In Juneconstruction in thea Boiling 1973, I attended Commissios's Region !!!

Cater Reactor Technology Course for Commission inspectors.

The twelve day course, ccnducted by General Electric at the Ceneral Electric training Center near Commonwealth Edison's Dresden St& tion, covered boiling water reactor systems and equipment.

I vent t) wrth for Commonwealth Edison in the fall of 1974. I was hired by the Production Manager to supervise training in

  • the Company's generating stations. During my indoctrination, I attended a course on the Zion plants' Terhnical Specifications. The course prepared operators for the Atomic Energy Commission's examinations f or operator and Senior Zion Station by an operator. Instructior was given at instructor from General Physics. I also attended short courses en simulators for both Pressurized Water and Boiling Water Reactors.

I am enclosing two resumes to show my experience in the commercial nuclear power field.

In 1982, after leaving commonwealth Edison, I assisted a New York law firm The firm law suit over in arepresented the Three Mile Island Babeack and Wilcox. General 3 accident.

Public Utilities blamed the accident on Babcock and Wilcox.

proved that the fault was Metropolitan Edisun's, the plant's licensee.

Changes have been made in the commercial nuclear power program as a result of the Three Mile Island accident. The industry is better prepared to cope with a nuclear accident.

But the Nuclear Regulatory Commission's new Regulation is a setback. The new Regulation authorizes a Senior Operator to depart from technical specifications in an emergency.from In an emergency, a Senior operator is authorized to depart technical specifications if it is not immediately appirent to him that following technical specifications is providt,g protection.

~

8811170367 001109 PDR ADOCH 05000010 H l'l>H 1

At Three Mile Island, three minutes five seconds after the reactor scram, the reactor operator turned of f an emergency signal and shut dovn the high pressure injection system. The operator shut down the high pressure injection system to prevent an extended plant outage because twice this safety system had pumped sodium hydroxide into the reactor coolant system. (NUREG-0600;pgst!-1-44;I-2-49;!-2-50;!-4-11)

Despite the requirements of Three Mile Island's Technical Specifications, the Senior operator approved shutting down immediately apparent to the the safety system. It was not Senior Operator that following Technical Specifications was protecting the integrity of the .eactor's nuclear fuel. It was not immediately apparent to the Senior Operator that following Technical Specifications was protecting plant workers and the public from the hazardous radiation of the fuel's fission products. The Senio't operator was working to get the plant back on line as soon as possible.

The Nuclear Regulatory Commission's new Regulation, 10 CFR 50.54 (x) and (y), is supert'luous. To protect public health and safety from the ha:ardsf rom of nuclear radiation, technical rath<' than specifiestP ,

giving authority to depart '

instruct Senior Operators to f ollow technical specifications.

The Nuclear Regulatory Commission's new Regulation is 4 superfluous and dangerous.

Sincerely y urs, 61 1 ~)

Chatles You'.q Enclosures copy to Ms. Mary Bushnell chair ma n -

Illinois commerce commission

c Charles Young 262 Sheffield Lane Glen Ellyn, Illinois 60137 312 469-0267 EXPERIENC[

Six years with Commonwealth Edison Company, Chicago,1111 noir (19741sJ1). '

Commonwealth Edison has seven operating r:velear plants and Supervised six plants under construction. Worked for Division Manager, Nuclear Stations.

Investigated operating pro-development of nuclear statior. training programs. Identified cauces, determined tolutions and blems at raclear stations. Ten months developing training programs at a nuclear station under tive action.

construction.

Inspected commer-Two years with the Atomic Energy Commission (19721974). Inspected i,1) constru cial nuclear power plants under construction. Inspected quality assur-structural, piping, electrical, components and equipmer.t.

ante programs of Utilities. Architect Engineers, and Co* tractors.

Commanded a squad- ,

Thirty years active duty, United States Navy (1941-197?).Com.anded three sab. -

ren of eight nuclear powered ballistic missile submarines.

marines - a nuclear powered ballistic missile submarine and two dieselDuties submarines.

ashore:

Duties at sea in a destroyer, submarines, aircraf t carriers, cruiser.

Officer in Charge Subr.arine School; Staff assignments in Washington, D.C. and Nor Virginia. Flight Instructor Pensacola, Florida.

EDUCATION AND SCHOOLS: '

U.S. Naval Acade?y F.S. Ccncrete Construction Course U.S. Arny Corps of Engineers haval Nuclear Power Course NDT Courses: M', PT, UT, RT, Eddy Current Pelaris Missile Comnand Cource SWR Technology (ourse Subnarine School General Electric Naval Flight Training IWR Sinulttor Arred Forces Staff College Short Courses: l PWR Simulator National War College Pf 450'iUg :

Marr,ied - S Children 1 Dav;hter,17, in College. 7 Born - Jv!y 3, 1920  !

f

l- ,

CHARLES YOUNG 262 Sheffield Lane Glen Ellyn, Illinois 60137 (312)790-2288 t

October 1983 EXPERIENCE IN QUALITY AS$URANCE/ QUALITY CONTROL .

Reactor Inspector; U.S. Atomic Energy Comission; Region !!!; 1972 1974 f Principle inspector at 4 nuclear plants under con- i i struction. Inspections at 3 other plants under construc-l tion.  !

l Preparations for inspection made by reviewing Construc-l tion Permit, Preliminary Safety Analysis Report. Codes and ,

1 Standards, l Inspected the QA/QC programs for the utility and [

l contractors at the con'truction site.  !

Inspections based an 18 point criteria of 10 CFR 50 i Appendix B. Inspected all phases of QA/QC programs:

documentation; receipt and storage of material and equip- '

ment;workinthefield;andtestingiplines:

Inspected all construction disc structural;

, piping; electrical; in:trumentation; installation of compo- l

! nents and equipment.

Usually made 2 inspect 19s each mouth; three days at [

site. .

Reviewed results at er.it conference. Wrote official l AEC report. Cited violations of AEC rules and regulaties. I Made follow up inspections and verified corrective  ;

action for violations.  !

Principal inspector at Zion 2. D.C. Cook 1 and 2; Davis i Fesse 1. Also made inspections at Zion 1. Cuane Arnold, and  !

Kewaunee.

Reviewed QA progra at headquarters of following 1 utilities: Kansas Gas & Electric; Union Electric $ Northern l States Power; Rochester Gas & Electric; Toledo Edison; [

Cosvnonwealth Edison. And the following architect engineers: l Bechtel. Gaithersburg, M' Sargent ! Lundy Chicago. IL. ,

i Compliance Administrator uwe.talth Edissu Company. Chicago. !L; 1977 1980 t i

Work based on Coere .alth Edison't Quality A0surance  !

Program for Construction and Operstions. 6 operating i nuclear plants; 6 plants under construction.

Worked to prevent and remedy violations of NRC roles and regulations. Reviewed Station's Operating License / Tech-nical Specifications; CE Quality Assurance Programt NCC rules and regulations. Worked at stations to ider'.ify problems and causes, and determined corrective accion.

_