ML20207B103

Urges Cancellation of Paragraphs X & Y of 10CFR50.54 Re Tech Specs & Policy for Operating Nuclear Plants, Respectively

ML20207B103
Person / Time
Site:	Dresden
Issue date:	04/18/1988
From:	Cale Young AFFILIATION NOT ASSIGNED
To:	Zech L NRC COMMISSION (OCM)
Shared Package
ML20206D924	List: ML20206D920 ML20206D945 ML20206D950 ML20206D971 ML20206D992 ML20206D997 ML20206E005 ML20206E028 ML20206E036 ML20206E043 ML20206E070 ML20206E074 ML20206E086 ML20206E090 ML20206E095 ML20206E228 ML20206G865 ML20207B103
References
NUDOCS 8807180158
Download: ML20207B103 (5)

Text

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ta r', M-t 262 Sheffield Lane q e' , ') P Glen Ellyn, II. 60137 April 18, 1988 ,3 g+ \3 /hs) E' ,egd

,I s k1 Mr. Lando Zech Chairman k

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U.S. Nuclear Regulatory Commission  ;\a+ (

Washington, D.C. 20555

Dear Lando:

In May 1987, I made a formal Complaint to the Illinois the Commerce Commission against Commonwealth Edison Company, Chicago based utility. I complained that commonwealth Edison risks the health and safety of Illinois citizens when operating nuclear power plants in northern Illinois.

During proceedings 'onducted by the Illinois Commerce I

Commission, Commoni calth Edison's lawyer acknowledged that I w,e b Company officials authorize work in a reactor containment versel with the reactor producing power at Dresden and Quad __3 i Cities Stations. The lawyer also acknowledged that Company q officials authorize into a nuclear operators reactor to turn by a safety off water system being before the pumped system G( .1;W--

has finished its job during an emergency. Commonwealth Edison's lawyer moved that my Complaint be dismissed because the Nuclear Regulatory Commission resolved these issues in 1982 and nuclear saf ety is a matter under federal jurisdiction, i for The Illinois Commerce Commission dismissed my Complaint 1988, the l want of jurisdiction. In a letter dated January 13, write to Chairman of the Commerce Commission suggested that I Region III of the Nuclear Regulatory Commission.

i On January 29, 1988, I wrote to the RegionalI Administrator, cited the Nuclear Regulatory Commission, Region III.

hazardous practices at Commonwealth Edison's nuclear 1986,powerI l

plants. In a follow up letter dated February 24, wrote that employees work near a nuclear reactor producingbut power at the Company's Dresden and Quad cities Stations, risking a fuel meltdown by turning off a safety system can i

occur at any Commonwealth Edison nuclear power plant. ,

Mr. Charles H. Weil, Investigation and Compliance Specialist, acknowledged my letters. In a letter dated March 31, 1978, l Mr. Edward G. Greenman, Director Division of Reactor  :

Projects, replied to my complaints.

Mr. Greenman writes that the Nuclear Regulatory Commission approves of employees working in a reactor containment vessel l

when the reactor is producing power at Commonwealth Edison's Dresden and Quad Cities Stations. Mr. Greenman writes that when workers are inside the cont.ainment vessel with the l

8909/86/19-X 1

t reactor producing power, the containment vessel is always deinerted. But Dresden Unit 2 Technical Specification 1.7.A.S.a. requires that the containment vessel be inerted -

onygen concentration reduced to less than 5% with nitrogen -

during reactor power operations. Commonwealth Edison officials therefore violate Operating Licenses and Technical Specifications when they work employees in a reactor containment vessel with the reactor producing power at Dresden and Quad Cities Stations.

Mr. Greenman also writes that the Nuclear Regulatory Commission approves of employees working in a containment vessel with the reactor producing power because Commonwealth Edison officials ensure that the radiation dose limits of 10 CTR part 20 are not exceeded. But 10 CFR part 20 reads, in cddition to complying with stipulated dose limits, officials chell make every reasonable ef f ort to maintain radiation oxposures of nuclear plant employees as low as reasonably ochievable. Because of high radiation levels, General E'eectric engineers designed the boiling water reactors at Dzesden cnd Quad Cities to operate without workers entering the containment vessel during power operations (General

~ Electric Manuals NEDO-10128 and NEDO-10260). Commonwealth Edison officials therefore violate 10 CFR part 20 and plant ,

Operating Licenses, when they expose workers to hazardous radiation by sending them into a reactor containment vessel with the reactor producing power at Dresden and Quad Cities Stations.

Mr. Greenman writes that the Nuclear Regulatory Commission censiders it reasonable to turn off a nuclear plant safety system in an emergency. But Federal Regulations require a nuclear plant safety system to pump water into a nuc1Lar reactor as long as the abnormal condition which activated the system, persists. Commonwealth Edison's policy permits operators to turn off water being pumped into a nuclear reactor during an emergency before the safety system has finished its job. Turning off water being pumped into a nuclear reactor during an emergency, can cause a nuclear fuel meltdown. Commonwealth Edison's policy can cause a nuclear fuel meltdown, release of highly radioactive fission products, and exposure of plant personnel and people nearby to hazardous radiation. Mr. Greenman writes that the Nuclear Regulatory Commission affirms this policy - a policy that can cause an accident like Three Mlle Island.

Regarding the Three Mile Island accident, Victor Stello writes:

" .. had the operators allowed the emergency core cooling L

system to perform its intended function, damage to the core i

would most likely have been prevented." (FORWARD to NUREG-  ;

l 0600, fifth paragraph) '

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• 4 In July, 1979, Mr. Stello conmissioned a Special Review Group to review the lessons learned from the Three Mile Island Cecident. The Special Review Group found if operators had cdhered to Technical Specifications, the high pressure injection system would not have been throttled with the reactor coolant system at low pressure conditions. (NUREG-0616, pgs 87, 86)

Three official investigations confirm that operating Three Mile Island as required by the Operating License and Technical Specifications, would ha , vented danage to the nuclear reactor:

(1) The president's Commission found that reactor core damage would have been prevented if the high pressure injection '

cystem had not been throttled. (Kemeny Commission Finding #4, pg 28)

(2) Calculations by the Special Inquiry Group show that use '

of the high pressure injection system would have prevented overheating of the thel and release of radioactive material.

(Rogovin Vol II part 2, pgh D.2.b, pgs 558,561)

(3) The Special Investigntion by the Senate Subcommittee on Nuclear Regulation isund the cause of severe damage to the reactor core was the inappropriate overriding of automatic safety equipment by plant operators and managers. (Hart ,

Report Chapter 2, Findings and Conclusions, 92, pg 9)

The Nuclear Regulatory Commission issued a new Regulation on June 1, 1983. This Regulation, 10 CFR 50.54 (x) and (y),

authorizes a Senior Operator in a nuclear plant to deviate from technical specifications in an emergency. Technical specifications prescribe settings for nuclear plant safety s ys t e ms . Settings f or automatic protective systems -

emergency core cooling systems for example - are defined so that action of a saf ety system will correct an abnr.rmal condition before fuel design limits are exceeded. Technical Specifications require an automatic safety system to operate l

as long as the abnormal condition which threatens the nue. lear fuel exists in the plant. Following technical speciflcations during an emergency leads to plant safety. Safety will not require a Senior Operator to deviate from technical l

, specifications. Mr. Stello believes that following technical l specifications is the safe way to operate a nuclear plant 1.

t To protect public health and safety from the hazards of .

nuclear radiation when nuclear energy is prodJCing power, I l

j urge you to cancel Federal Hegulation 10 CFR 50.54 paragraphs g,;<

(x) and (y). Enclosed is a draft to replace these paragraphs.

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' Sincerely yours, d'; 7 ~~l charles Young 3

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F 1 On December 31, 1984, the Office of Nuclear Reactor R0gulation established a Technical Specification Improvement Project to consider the entire subject of Technical Specifications and provide recommendations for improvement.

The Group concluded that problems identified with Technical Specifications do not pose an acute safety problem for Operating power reactors. Mr. Stello sent the Report to the Ccmmissioners in a letter dated January 13, 1986. In his lotter, Mr. Stello endorsed the principal finding of the Group. The Group's principle finding is that.there are no ceute safety concerns associated with Technical Specifications which support a mar:iatory program of changes to the Technical Specifications of operating reactors.

Enclosure Copy to:

Ms. Mary Bushnell .

Cha ir ma n Illinois commerce Commission 4

Section 50.54, Title 10, DRAFT - Suggested change to part 50, Code of Federal Regulations.

850.54 conditions of Licenses.

(xi The Atomic Energy Act of 1904 stipulates that a in licensee shall operate a commercial nuclear power plant cecordence with technical specifications. Technical Opecifications define the specific characteristics of a nuclear power plant which ensure that iuel design limits are not exceeded during normal operations and emergencies. By review of a nuclear power plant's safety analysis and technical specifications, the Nuclear Regulatory Commission determines that utilization of special nuclear material will be in accord with the conson defense and security and will provide protection to the health and safety of the public. To prevent fuel damage and protect public health and safety from the hazards of nuclear radiation, a licensee shall follow technical specifications when operating a commercial nuclear power plant.

(y) The Chief Executive Officer of a public utility or other organization licensed to operate a commercial nuclear power plant shall establish pclicy for operating the plant.

The Chief Executive Officer shall direct that the nuclear power plant be operated in accordance with the Operating License and Techrical Specifications."

References:

(1) Atomic Energy Act of 1954, Section 2232 (2) Code of Federal Regulations, Tirle 10, part 50 Sections 50.34, 50.36, 50.46, 50.57, and Criterion 10, APPENDIX A.

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262 Sheffield Lane 'O Glen Ellyn, IL 60137 >

February 24, 1988 m o -, , , ,

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J' ~ ~ W" M Mr. Charles H. Weil , g o" ,' ,'

Investigation and compliance Specialist '

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'".1 #. . ' , .st '3 U.S. Nuclear Regulatory Commission, Region III Post Office Box 2027 60138-2027 13 Olen Ellyn, Illinois vM J

Dear Mr. Well:

y My letter of January 29, 1988, describes two safety problems 9 -

ct Commonwealth Edison nuclear power plants. The first - ~~}~ TLv &

working employees near a nuclear reactor producing power -y#> 2-cccurs at Dresden and Quad Cities Stations. Risking a fuel'] -4 y-meltdown by turning of f a safety system, can occur at any Commonwealth Edison nuclear power plant.

The Energy Reorganization Act of 1974, places responsibility for safety on officers of companies operating nuclear power plants. Section 206 of the Act reads that an officer of a firm operating a nuclear plant who learns of a plant defect which could create a substantial safety hazard, r5all

• immediately notify the Nuclear Regulatory Commission.

A Commonwealth Edison Company Policy authorizes operators to turn of f 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 low, temperature stable but high, and level stable but low, the reactor's nuclear fuel can be burning up.

An operator at any Commonwealth Edison nuclear power plant can cause serious damage by following instructions issued by Company officers. Turning off water being pumped into a nuclear reactor by a safety system bef ore the syr tem has i finished its job, can cause the meltdown of a reactor's nuclear fuel.

A copy of the defective Policy is enclosed. I have underlined one of the defects in the Policy.

Very respectfully, bi ul- 9 --n Charles Young Enclosure 1 '/pp.

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I copy to:

Mary B. Bushnell, Chairman Illinois commerce Commission Illinois Department of Nuclear Safety I

Lando Zech, Chairman

- U.S. Nuclear Regulatory Commission i.

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VICE PRESIDENT'S INSTRUCTION NO.1-0-17 f SU3 JECT: Company Policy Regarding safe Operations and Adherence to

( Nuclear Procedures and Effective: August 18, 1986 Technical Specifications Cancels: V.P. Instn 1-0-17 ($-23.g3) ,

1 I

This lastruction reaffirma Company policy regarding adherence to nuclear procedures and technical specificathns.

l The prunary 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. l 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 l during his shift. t l

In order to achieve this safety goal, plant operation is to be within the ~

t boundaries specified in our technical specifications and in adheree:e to procedures and operating orders. Systems which could affect the public health and safety >

(including energency core cooling system, red-waste, etc.) are to remain operable as prescribed in the technical specifications.

It is recognised that circumstances may arise which were not foreseen in the #

For example, a combination of events which l preparation of technical specifications.

were analyzed individually may, taken together, produce results which were not In these i

{ expected or analysed during reviews leading to the technical sp![

cause, rather than prevent, problema. If such circumetances should arise, prudence i I

may require operation outside of the technical specifications, procedures operating orders. l probles and only after careful consideration and orapprovall (1) injury to the public i

Operator immediately available in order to prevent l Company personnel (2) releases off-site above technical specification limits, or (3 j i

desage to equipment Af such damage is tied to a possible adver health and safety.

license conditions and technical specifications is immediately apparent which can provide adequate or equivalent protection.

l Further, it say bt necessary upon occasion to taanorarii, withdraw Thisa averam should_ f j

er systems f rom opey_ation by niacina it in a manual or null-to-lock mode.

r be done only when c anditions are "stable and under centro 1L or when it isThe apparent conditical that continued opet acion would aggravate or worsen the plant condition.  :

of "stable and under control" are considered to exist (1) if the radiatio the pressure and temperature in the primary containment are stable, and (2) if thel ,

d is adequate core temperatures and levels.

coolina as _ indicated by stable reactor coo 1~ ant avs j

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careful consideration, and Ititismust not expected be reviewed and appro that such operations will  !

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be conducted for prolonged periods. l l  !

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Ill. C. C. Docket 87-0228 Exhibit A I

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VICE PRESIDEST'S 1h5IhuGI40h NO. 1-0-1/ 1

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.8418 46)

Whenever a system is withdrawn from operation as outlined, continuing surv:111&nce of ths relevant parameters must be maintained by a licensed Reactor

>peret r to assure the safe operation of the plant until the system can be restored ,

9 mormal operability or until it is no longer needed, as prescribed by the

cchnical specifications.

In all cases noted above, when the technical oper.ification boundaries are raceeded or when a system is withdrawn from operation:

The Station Shift Engineer shall be notified immediately.

. The Shift Technical Advisor / Station Control Roon Enlineer shall be consulted to determine whether immediate shutdown, orderly power reduction, or other course of action is appropriate.

The Station Manager or his designate shall be notified who in turn shall notify the Nuclear Duty Officer in accordance with established procedures. ,

The NRC Operations Center shall be notified by telephone. When time permits, the notification must be made before tha protective action is taken; otherwiss, r.he notification must be made as soon as possible thereafter.

A report shall be promptly made to the Division Vice Frasident -

Nuclear Stations. .

A plant shutdown, immediate or by power reduction, shall be cemmenced unless prolcnged operation under the circumstances is concurred in by the NRC in the case of operating outside the technical specifications. In other cases the Station Manager or his designate may authorize prolonged operation if appropriate.

All station personnel shall be informed of this policy and it shall be lacluded in our training program.

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Vice President

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