Re: Accident Consequences

[LIPTONW@detroitedison.com]

You wrote: 
 
If a change was made to your facility that required an 
operator action to mitigate the consequence of an 
accident.  Would the operator dose required to perfom 
the action (in itself) be considered an increase in the  
consequence of the accident?  
 
gwkindred@FirstEnergyCorp.com 
 
There are two parts to this: 
 
(1) Generally, the radiological  consequences of 10CFR50.59 refer to offsite 
dose.  Operator dose is a factor, however, if it impedes accident mitigating 
actions, eg., the increase in dose rate renders an area inaccessible or 
reduces stay time below that required to perform the needed actions.   
 
(2) The reliance on operator actions instead of automatic actions as a result 
of the proposed change may, in itself be an unreviewed safety question.  See 
NRC Information Notice 97-78, "Crediting of Operator Actions in Place of 
Automatic Actions and Modifications of Operator Actions, Including Response 
Times". 
 
The opinions expressed are strictly mine. 
It's not about dose, it's about trust. 
 
Bill Lipton 
liptonw@detroitedison.com