IR 05000346/1992004

Ack Receipt of Informing NRC of Steps Taken to Correct Exercise Weakness Noted in Insp of Annual Emergency Preparedness Exercise on 920513,per Insp Rept 50-346/92-04

ML20126H157
Person / Time
Site:	Davis Besse
Issue date:	12/28/1992
From:	Norelius C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Shelton D TOLEDO EDISON CO.
References
NUDOCS 9301050084
Download: ML20126H157 (3)

Text

- .. - _ _ _ _ _ _ _ _ _ _ _ _ _ - _ - _ _ _ - _ ._

_ _ - _ .

.

'

() t, D l

DEC l' B 1932 Docket No. 50-346 Toledo Edison Company A11N: Mr. Donald Shciton Vice President Nuclear Davis-Besse Centerior Service Company 300 Madison Avenue Toledo, OH 43652

Dear Mr. Shelton:

SUBJECT: EXERCISE WEAKNESS ASSESSED DURING THE 1992 Al4NUAL EliERGENCY PREPAREDNESS EXERCISE AND ADDENDUM 10 INSPECTION REPORT NO. 50-346/92004(DRSS)

We have received and reviewed your response, dated October 6, 1992, to an exercise weakness which was identified during the inspection of your annual emergency preparedness exercise on May 13, 1992, as documented in inspection Report No. 50-346/92004(DRSS). Our review of your response was performed independently by the emergency preparedness and the radiological controls staffs.

We agree with your assessment that internal exposure evaluations during exercises, actual events, and day-to-day operations should be in accordance with your existing radiation protection program. Our intent was not to imply a generic problem with your radiation protection program. Instead, we identified what we perceived to be a performance weakness concerning the implementation of your radiation protection program during your exercise.

Your response stated that "the l'RC Region 111 staff position is that respirators are required for inplant teams, unless local air sampling is performed which indicates that any potential internal exposure is of no concern. No regard is given to other available indications." This is not the Region 111 staffs' position. We recognize there are other valid methods of obtaining information to base the decisions on the use of respirators. Your response described the information your staff used to determine if respirators were required during the May 13, 1992 exercise. From our review of this information, we agree that your method was appropriate and we, therefore, withdraw the exercise weakness, However, we did not observe these methods being implemented during the exercise. Therefore, to ensure these decisions are observed during the next exercise, this concern will be tracked as an inspection followup item (346/92004-01(DRSS)).

9301050004 921220 gDR ADOCK 05000346 PDR 3[

g' 40 j

_

.

l

Toledo Edison Company 2 DEC ?. 01932 Your response also discussed a sub-issue of the exercise weaknass concerning what we identified to be an inappropriate decision to issue )otassium iodide (KI). You stated that a decision was not made to issue K1, >ut rather a discussion was held concerning using K1 if an annulus entry was necessary.

You also stated that, as a conservative measure, authorization to issue K1 was delegated to the Emergency Plant Manager, in anticipation of its use but that its actual use would have required an evaluation per HS-EP-02620, Emergency Exposure Control and Potassium lodide Distribution. Because an annulus entry did not occur, the evaluation was not performed and KI was not issued.

Although your statecents conflict with the conclusions of our observers who were present during most of the K1 discussions, we acknowledge them. Again, to ensure that ap3ropriate discussions and decisions are made concerning ,

issuance of Kl. t11s concern will be tracked as an inspection followup item (346/92004-03(DRSS)).

t We appreciate the additional information on this concern and acknowledge that there is some disparity between the observations of the inspectors and your '

internal assessment. We will closely evaluate decision making related to the use of respiratory protection and K1 during your next annual emergency exercise to ensure that these concerns are resolved.

If you have any questions regarding this issue, please contact Mr. J. McCormick-Barger of my staff at (708) 790-5284.  ;

Sincerely,

!

ontct!!At.Utta M CW W L W S D Charles E. Norelius, Director Division of Radiation Safety l_

and Safeguards cc: L. Storz, Plant Manager DCD/DCB (RIDS)

OC/LFDCB Resident inspector, Rlll State Liaison Officer, State of Ohio Robert E. Owen, Ohio Department of Health A. Grandjean, State of Ohio, Public Utilities Commission

Rlli Rlli Rlll 9MS'h Ril)},[

({ grb9 ick-Barger/dg Lanksbury Pe erson hof611us McCorp/92 12/.3 *eege 4 4 J/j,2 #2hr/92 c odCWf

- . . - .. - - -. . _ - , . . ..

_ _ . _.- _ _ _ _ -._. _ _ _ _ _ _

.

.

I Toledo Edison Company 2 Your response also discussed a sub-issue of the exercise weakness concerning what we identified to be an inappropriate decision to issue 30tassium iodins.g'c,gg (KI). You stated that a decision was not made to issue Kl )ut rather a discussion was held concerning using K1 if an annulus entry was necessary.

You also stated that, as a conservative measure, authorization to issue-KI was delegated to the Emergency Plant Manager, in anticipation of its use but that its actual use would fiave required an evaluation per HS-EP-02620. Emergency Exposure Control and Potassium lodide Distribution. Because an annulus entry did not occur, the evaluation was not performed and K! was not issued.

Although your statements conflict with the conclusions of our observers who were present during most of the K1 discussions, we acknowledge them. Again, to ensure that ap)ropriate discussions and decisions are made concerning issuance of KI, t11s concern will be tracked as an inspection followup item (346/92004-03(DRSS)).

We appreciate the additional information on this concern and acknowledge that there is some disparity between the observations of the inspectors and your internal assessment. We will closely evaluate decision making related to the use of respiratory protection and K! during your next annual emergency exercise to ensure that'these concerns are resolved.

If you have any questions regarding this issue, please contact .

Mr. J. McCormick-Barger of my staff at (708) 790-5284. .

Sincerely,

Charles E. Norelius, Director Division of Radiation Safety and Safeguards cc: L. Storz, Plant Manager DCD/DCB (RIDS)

OC/LfDCB Resident inspector, Rlll Stata Liaison Officer, State of Ohio Robert E. Owen, Ohio Department of Health

A. Grandjean, State of Ohio,.

Public Utilities Commission l

Rill Rill RIII RIII Qmd (o f McCormick-Barger/dg Laqksbury Pederson Norelius 12/24/92 PlH%

L:

_. - = -

- .- . _. . - . _ _ . _ . - __ .. _ _ _ _ _ _