ML20042E044
| ML20042E044 | |
| Person / Time | |
|---|---|
| Site: | Dresden, Byron, Braidwood, Quad Cities, Zion  |
| Issue date: | 04/09/1990 |
| From: | Taylor J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | David Williams NRC OFFICE OF THE INSPECTOR GENERAL (OIG) |
| Shared Package | |
| ML20042E047 | List: |
| References | |
| NUDOCS 9004190108 | |
| Download: ML20042E044 (2) | |
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APR 0 91990 MEMORAN'DUM FOR: David C. Williams-Inspector General Office of the Inspector General FROM:
James M. Taylor Executive Director for Operations
SUBJECT:
LETTER FROM CHARLES YOUNG
[
Your March 23, 1990, memorandumL forwarded a letter from Mr. Charles Young concerning the Comonwealth Edison Company Vice President's' Instruction No. 1-0-17.
The staff has reviewed the letter and concludes that it does not contain any new information. As discussed in the enclosed March 31, 1988, letter to Mr.. Young, the staff previously reviewed Instruction No. 1-0-17 and found that-it was in compliance with the requirements of 10CFR50.54(x)and-(y).
Based upon our review of Mr. Young's recent letter and our previous
' reviews ^ of this matter, I conclude that-no additional action is necessary.
Griginal Signed By:
James M. Taylor
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James M. Taylor Executive Director for Operations
Enclosure:
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i Docket No. 50 237 Docket No. 50 249 u
-Docket No. 50 254 i
Docket No.-50-265 l
Mr. Charles Y'oung.
262 Sheffield Lane Glen Ellyn, IL 60137
$UBJECT: ALLEGED HAZARDOUS. PRACTICES AT COMMONWEALTH EDIS0N NUCLEAR
' POWERPLANTS.(A!TSNO.F03004988)
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. We received your letters dated ' January 29 and February 24,'1988,- that-provided' j
.your concerns of alleged hazardous practices at~ Commonwealth Edison Nuclear-Pl a nt s ',
in general tems your concerns were:
(1) employees work near a nuclear..
reactor producing power at Dresden.and Quad Citfes Stations endangering their-1 eyes and violatin containment:requirementsi; and (2) the company. risks a nuclear j
fuel meltdown by authorizing operators to turn off a nuclear _ plant safety _ system j
during'an emergency.
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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 concluded:that such work is only infrequently performed and then only within-established restrictions on powerilevel'and radiological L
monitoring. The normal operating condition is -for~ the drywell: to.be t
inerted, and barred to personnel access.::The restrictions were' established in acknowledgement-of the: increased radiological environment as 'well as the; 1
increased potential for nonradiological: safety hazards. -
Several years ago Dresden and Qua' Cities: Stations had Battelle Pacific d
Northwest Laboratories determine neutron energy and flux in1.their drywells at power to ensure that their neutron survey. instruments:and dosimeters properly' determine ~ neutron dose equivalent rate and dose for persons entering at power. The neutron dose equivalent rates measured inside p
Dresden Unit 3 drywell while the reactor was operating at 20% power varied L
from 0.3 to-1.0 mrom/hr as measured by Battelle-Pacific Northwest Laboratories J
on May 4. 1985, using a tissue equivalent proportional counter and He-3=
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~ spectrometer in conjunction with the licensee's; survey instruments and L
personnel neutron dosimetry.
Five different locations were chosen in the E
drywell for the measurements; These locations were chosen to be represent-E 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 4
than the gamma dose rates at all: locations. iln.accordance with' plant l
procedures, drywell entries during plant power operation will only occur t
with: reactor power at or below 40%, and will be performed by management T :
personnel. Our procedure reviews and inspections have'found that (1) this r;
type of entry is usually to determine the' source of leakage from' the primary 1
systemorforanequipmentinspection;_(2)thatundernoconditionswill.a-J drywell entry be made when the drywell-is inerted; (3) that permission to make a drywell entry has to be first approved by either the Production-M, ne
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Mr. Charles Young 2 M II E 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.
1 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. pre w res regarding employee exposure to radiation have found them to be in 9 Jrdance 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 Comonwealth Edison Company has.-imposed sufficient controls to minimize these hazards while accommodating 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 Specification. 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 prior'to taking the-action _
in addition, the NRC will review any circumstances ehere 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 licensee's procedures and, in particular, the policy you referenced, "Vice President's Instruction No.1-0-17," 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.
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Mr. Charles Young' 3
MAR 31 1988 i
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 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 af ter careful con.
sideration, 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 i
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 found to be in accordance with the ~ regulations.
l Based on the discussion above, we do not agree that your concerns represent l
violations of federal regulations. Since no violations of our requirements have been identified, no further action is intended at this time._
this adequately addresses your concerns.
1 hope-Sincerely.
Original Signed by M. J.-Virgilio Edward G. Greenman, Director Division of Reactor Projects 4
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Attachment:
Inspection Report:
50-237/81-39OPRP) 50-249/81-32 DPRP) 1 50-254/81-23OPRP) 50-265/81-23 DPRP) 1 50-295/81-31(DPRP) 6 50-304/81-29(DPRP) 1 cc w/ attachment:
Thomas Rehm. ED0 Assistant for Operations pC Y6
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WASHINGTON, D, C. 20555 EDO Principal Correspondence Control l
FROM: ~
DUE: 04/09/90 EDO' CONTROL:-0005293--
DOC DT: 03/23/90 FINAL REPLY:
-D6vid C. Williams
'OIG
.TO:
-JEm M M. Taylor
-FOR SIGNATURE OF:
- GRN CRC NO:
ExecutiveLDirector ROUTING:
-DESC:
ENCLOSES LETTER FROM CHARLES YOUNG REGARDING Taylor-COMMONWEALTH EDISON POLICY FOR OPERATING. NUCLEAR Thompson.
Blaha
~ PLANT SAFETY SYSTEMS Davis, RIII-l lDATE: 03/26/90 Norry,-ADM
-AbSIGNED-TO:
CONTACT:
(
NRR Murley
~
LSPECIAL INSTRUCTIONS.OR REMARKS-
.. ADVISE OIG AS TO WHAT ACTION, IF ANY~, IS NEEDED.
t NRR RECEIVED: MARCH 26,'1990 SACTI.0N:)
rROSSIE(C00RDINATECWITH"ALLEGATIONt: REVIEW! BOARD)J NRR ROUTING:
MURLEY/SNIEZEK PARTLOW
.MIRAGLIA CRUTCHFIELD GILLESPIE EES ACTION.
i M0SSBURG DUE TO NRR-DIRECTOR kk n
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