ML20054C674

Revised Contentions 10-12.Certificate of Svc Encl

ML20054C674
Person / Time
Site:	Byron
Issue date:	04/15/1982
From:	Chavez D DEKALB AREA ALLIANCE FOR RESPONSIBLE ENERGY, SINNISSIPPI ALLIANCE FOR THE ENVIRONMENT (SAFE)
To:	NRC COMMISSION (OCM)
References
NUDOCS 8204210489
Download: ML20054C674 (3)

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Sinnissippi Allianco for the Environmant 326 Noch Avon Street Rockforc, Illinois 61103 UNITED STATES OF AMERICA -

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NUCLEAR REGULATORY COMMISSION In the Matter of ) Docket Nos. 50-454

) 50-455 COMMONWEALTH EDISON CO., )

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Syron Station )

(Units No. 1 and No. 2) 4 b

DAARE/ SAFE'S REVISED CONTENTIONa 2 (April 15, 1982) [ ~.

hi ,. ' c 31902 F'" , 57.

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Contention10- /' )N

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r The Byron FSAR and SER contain inadequate assurance that Commonwealth Edison will maintain occupational exposures as low as is reasonably achievable, as required by 10 CFR Part 20. The assessment of collective radiation dose to workers from plant operations as described in section 12.4 of the FSAR is not con-sistent with the acceptance criteria in NUREG-0800, or ALARA, in-j sofar as the applicant's assessment 1s not based on an analysis

'of the tasks involved in the operation of the plant, the ex-l pected radiation dose rates, and the personnel required to per-i form those tasks", but upon an averaging of dosages recievod_during I

se'_ected activities at other plants; despite the following:

a. Edison's program regarding occupational radiation exposure presently relies upon use of transient and temporary work-ers to minimize allowable radiation exposures to individ-ual workers to meet regulatory limits, 5o3

b. Edison's occupational radiation exposure program does not provide for the recording of cumulative exposures which /D workers may receive at Byron and at other nuclear facilit-ies:

8204210489 820415 PDR ADOCK 05000454 G PDR

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c. Edison does not attempt to minimize occupational exposures to radiation as much as possible by basing work assignments in high risk areas upon factors such as individual volunt-eerism and assignments given to individuals with the least demonstrable suseptibility in age and health'to radiation effectss -

d. Edison's plant design does not take into account new evid-ence regarding the dangers of exposure to low levels cf radiation; and,

e. The Byron plant contains inadequate monitoring instrument-ation of sufficient quanity and sensitivity to detect var-iations of radiation; particularly alpha, beta, and gamma radiation.

Applicant should be required to reassess it's program regard-1 ing occupational radiation exposure and institute corrective action to include the above factors in it's program.

Contention 11 The turbine-generator placement and orientation at the Eyrron Units 1 and 2, as identified in SER, 3-10, are unfavorable rela-tive to station reactor buildings. Systems important to safety have been demonstrated to lie "inside the low trajectory missile strike zone." (Regulatory guide 1.115) This warrants relocation of the turbine-generator placement and alteration of it's exist-ing orientation.

1 Contention 12 Task Action Plan B-57 identifies the potential safety prob-lems associated with loss of off-site and AC power. In the etent of loss of off-site power at the Byron plant, the FSAR and S E.:.

demonstrate several failure possibilities in the conversion t0 alternative power systems due to Edison's reliance upon the fel-lowing inadequate power components. Several inadvertant and/ r unrelated failures in these components in the resultant power re-

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duction and systems interaction could render it impossible to oper-ate simulteneously the neccessary emergency equipment and safety systems components required to maintain safe reactor shut-down margins under Design Basis Criteria.

a. Applicant's reliance upon Storage OC Battery units for AC replacement which are subject to time constraints on oper-ability;

b. Applicant's reliance upon diesel generator coolant pumps; units which, as has yet to be determined, may be possibly defective units manufactured by the Heywood-Taylor Pump Co, now the subject of an investigation by NRC Region IV Office; these units may fail simultaneously; Certificate of Service The undersigned, a member of DAARE/ SAFE certifies that on this date, April 15, 1982, she served copies of these Revised Contentions on each member of the Service List, by Special Del-ivery, Regular U.S. Mail, or by other means as neccessary, i

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r. m., s .n - y Diane Chaven, DAARE/ SAFE Date: April 15, 1982 ene: Service List 4

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