ML17199V490
| ML17199V490 | |
| Person / Time | |
|---|---|
| Site: | Dresden, Quad Cities, 05000000 |
| Issue date: | 03/31/1988 |
| From: | Greenman E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Cale Young AFFILIATION NOT ASSIGNED |
| References | |
| NUDOCS 8804070265 | |
| Download: ML17199V490 (4) | |
Text
".
MAR 3 1 1989 Docket No. 50-237 Docket No. 50-249 Docket No. 50-254 Docket No. 50-265 Mr.. Charles Young 262 Sheffield Lane Glen Ellyn, IL 60137
SUBJECT:
ALLEGED HAZARDOUS PRACTICES AT COMMONWEALTH EDISON NUCLEAR POWER PLANTS (AITS.NO. F03004988)
We received your letters dated January 29 and February 24, 1988, that provided your concerns of alleged hazardous practices at Commonwealth Edison Nuclear Plants.
In general terms your concerns were:
(1) employees work near a nuclear reactor producing power at Dresden and Quad Cities Stations endangering their eyes and violating containment requirements; and (2) the company risks a nuclear fuel meltdown by authorizing operators to turn off a nuclear plant safety system*
during* an emergency.
- 1. *Regarding your *.concern about the hazards to employees working near reactors while producing power, while it is true that radiation workers perform work in the drywells at Dresden and Quad Cities nuclear power stations at.
power, we have ~oncluded that such work is only infrequently performed and then only within established restrictions on power level and radiological monitoring.
The normal operating condition is for the drywell to be inerted, and barred to personnel access.
The restrictions were established in acknowledgement of the increased radiological environment as well as the increased potential for nonradiological safety hazards.
Several *years ago Dresden and Quad Cities Stations had Battelle Pacific Northwest Laboratories determine neutron energy and flux in their drywells at power to ensu~e that their neutron survey instruments and dosimeters properly determin~ neutron dose equivalent rate and dose for persons.
entering at power.
The neutron dose equivalent rates measured inside Dresden Unit 3 drywell while the reactor was operating at 20% power varied from 0.3 to 1.0 mrem/hr as measured by Battelle Pacific Northwest Laboratories on May 4, 1985, using a tissue equivalent proportipnal counter and He-3 spectrometer in conjunction with the licensee's survey instruments and personnel neutron dosimetry.
Five different locations were chosen in the drywell for the measurements.
These locations were chosen to be represent-ative of the radiological conditions that would affect a worker in the drywell with the reactor at power.
The neutron dose rates were far lower than the gamma dose rates at all locations.
In accordance with plant procedures, drywell entries during plant power operation will only occur with reactor power at or below 40%, and will be performed by management.
~
personnel.
Our procedure reviews and inspections have found that (1) this
'\\
type of entry is usually to determine the source of leakage from the primary system or for an equipment inspection; (2) that under no conditions will a drywell entry be made when the drywell is inerted; (3) that permission to
~c...i\\
make a drywell entry has to be first approved by either _the Production
'.~
8804070265 880331 PDR ADOCK 05000237 p
Mr. Charles Young Superintendent or the Assistant Superintendent of Operations; and (4) that each individual entering the drywell while the reactor is critical wears neutron dosimetry in addition to beta-gamma dosimetry.
For persons entering the drywell, both the neutron and gamma doses are determined and are additive.
The licensee must ensure that 10 CFR Part 20 limits are*
not exceeded; these limits are set well below any known harmful effects to a person's whole body including the eyes~ Our inspections of Commonwealth Edison Company's programs and proGedures regarding employee exposure to radiation have found them to be in accordance with our
- regulations.
While we share your concern about increased radiological safety hazards incident to working in drywells at power, our inspections have shown that Commonwealth Edison Company has imposed sufficient controls to minimize these hazards while accoinmodating operational demands.
We will, however, continue to monitor the licensee's performance in this area through our inspection program to ensure their controls remain effective.
You also expressed a concern that drywell entries with the reactor operating violated containment requirements. Technical Specification 3.7.A.2 states, in part, that primary containment integrity shall be maintained at all times when the reactor is critical or when the reactor water temperature is above 212°F and fuel is in the reactor vessel.
Because of the double door airlock system on the primary containment,.
entry at power can be made without compromising containment integrity; therefore, Technical Specification 3.7.A.2 is met, and there is no violation of the operating license or the Atomic Energy Act of 1954.
This conclusion does not differ from the conclusion previously stated on page 70 of our Inspection Report 50-273/81-39; 50-249/81-32, which is attached.
- 2.
With regard to your concern with the authorization of operators to turn off a safety system during an emergency, this was reviewed in our inspection report 50-237/81-39; 50-249/81-32. This report acknowledged that situations may arise when it may be necessary to operate outside the station procedures or Technical Specifications (see pages 25 and 26).
Since that inspection report, Federal Regulation 10 CFR 50.54(x) has been issued which authorizes a licensee to take reasonable action that departs
- .from a license condition or a Technical Specifitation, such as turning off a safety system in an emergency.
This action is permitted when immediately needed to protect the public health and safety and no action consistent with license conditions and Technical Specifications that can provide adequate or equivalent protection is immediately apparent.
Federal Regulation 10 CFR 50.54(y) requires that any such action be approved, as a minimum, by a licensed senior operator prfor to taking the action.
In addition, the NRC will review any circumstances where a licensee invokes 10 CFR 50.54((x) to assure its appropriate use. This regulation has not been used at Dresden or Quad Cities to date.
The licen~ee's procedures and, in part-icular, the policy you referenced, 11 Vice President's Instruction No. 1-0-17, 11 have been reviewed and found to comply with the requirements of 10 CFR 50.54(x) and (y) therefore, there is no violation of the Atomic Energy Act of 1954.
Mr. Charles Young 3
MAR 3 1 1988 You also stated a concern that the licensee's operating policy would permit emergency core cooling to be turned off with stable reactor parameters of low pressure, high temperature, and low level resulting in core damage.
This hypothetical combination could not be interpreted as "stable and under control" as called for by the policy. If conditions existeq sufficient to cause core damage, then reactor pressure and level would have to be changing or other.
evidence of inadequate core cooling present such as reactor vessel level so low as to be out of the indicating range.
The policy also requires that:
In all such instances such actibn should be taken only after careful. con-sideration, and must be reviewed and approved by the licensed Senior Reactor Operator immediately available." This would preclude any i~dividual operator from independently taking such an action.
If operators are not permitted to exercise judgement in this area, the multiple emergency cooling systems with redundant capacities to add water to the reactor could cause other undesirable effects such as overfilling the reactor or injecting water from less desirable (due to cleanliness) backup sources. Obviously, safety system automatic actuations and Technical Specifications cannot prescribe actions for every combination of conditions, but are designed to meet the most extreme circum-stances.
The granting of authority to licensed reactor plant operators to
- respond in an emergency to protect the public health and safety was deemed necessary and was made a part of Federal Regulation (10 CFR 50.54(x) and (y)).
The Commonwealth Edison Company policy implementing this policy has been reviewed and fou~d to be i~ accordance with the regulations.
Based on the discussion above, we do not agree tha~ your concerns represent violations of federal regulations. Since no violations of our requirements have been identified, no further action is intended at this time.
I hope this ~dequately addresses your concerns.
Attachment:
Inspection Report:
50-23l/81-39(DPRP) 50-249/81-32(DPRP) 50-254/81~23(DPRP) 50-265/81-23(DPRP) 50-295/81~3l(DPRP) 50-304/81-29(DPRP) cc w/attachment:
Thomas Rehm, EDO Assistant for Operations
.ilh
- ~6~
r*
Riil RIII Rill
~
v11~/"/JJ;f-;1!,c.
.>f' Lerch/abl Ring
~J Weil Sincerely, Original Signed by M. J. Virgilio Edwa~d G. Greenman, Director Division of Reactor Projects
~~k
~
RIII~
rllf Green~,Pn
- pd <(l6
Mr. Charles Young Based on the discussion above, we do not agree that your concerns represent violations of federal regulations.
You stated a concern that the licensee's operating policy would permit emergency core cooling to be turned off with stable reactor parameters of low pressure, high temperature, and low level resulting in core damage.
This hypothetical combination could not be interpreted as "stable and under control" as called for by*the policy. If conditions *existed sufficient to cause core damage, then reactor pressure and level would have to be changing or other evidence of inadequate core cooling present such as reactor vessel level so low as to be out of the indicating range.
The policy also requires that: "In all such instances such action should be taken only after careful consideration, and must be reviewed and approved by the licensed Senior Reactor Operator immediately available." This would preclude any individual operator from independently taking such an action.
If operators are not permitted to exercise judgement in this area, the multiple emergency cooling systems with redundant capacities to add water to the reactor could cause other undesirable effects such as overfilling the reactor ot injecting water from less desirable (due to cleanliness) backup sources.
Obviously, safety system automatic actuations. and Technical Specifications cannot prescribe actions for every combination of conditions, but are designed to meet the most extreme circumstances.
The granting of authority to licensed reactor plant operators to respond in an emergency to proteci the public health and safety was deemed necessary and was made a part of Federal Regulation (10 CFR 50.54(x) and (y)).
The Commonwealth Edison Company policy implementing this policy has been reviewed and found to be in accordance with the regulations.
I hope this adequately addresses your concerns. Since no violations of our requirements have been identified, no further action is intended at this time.
Attachment:
Inspection Report:
50-237/81-39(DPRP) 50-249/81-32(DPRP) 50-254/81-23(DPRP) 50-265/81-23(DPRP)
- 50-295/81-31(DPRP)
- 50-304/81-29(DPRP) cc w/attachment:
Thomas Rehm, EDO Assistant for Operations
~
RIIij?i RI II
~/abl RII~
~g
,,~.. -,
Wei 1.,.
/J; 1fJ RIII Sincerely, Edward G. Greenman, Director Division of Reactor Projects RI I ~<v' Forney Gre~an RI II Paperi e 11 o