ML19330B939
| ML19330B939 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 07/14/1980 |
| From: | Crouse R TOLEDO EDISON CO. |
| To: | Heishman R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML19330B933 | List: |
| References | |
| NUDOCS 8008070244 | |
| Download: ML19330B939 (3) | |
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AcHamo P. CROUSE July 14, 1980 VJy'"
,s 44191259 5221 Docket #50-346
'b License #NPF-3 f
Serial No. 1-153 Mr. R. F. Heishman, Chief Reactor Operations and Nuclear Support Branch U. S. Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137
Dear Mr. Heishman:
This letter is in. response to IE Inspection Report No. 50-346/80-15, dated 5/12 - 6/10/80, (Log.1-388), as applicable to Davis-Besse Nuclear Power Station Unit 1.
Attached is Toledo Edison's response to Notice of Violation, items a.) and b.).
Yours very truly, y,y /
RPC/TDM/RPK/mdb Attachments
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$t THE TOLEOO EDISON COMPANY EDISON PLAZA 300 MAOISON AVENUE TOLEOO. OHIO 43652 RONS :I_E C03Y 8008070 2MM N*
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i e-Response to Appendix A, Docket #50-346 - Notice of Violation b
This submittal is pursuant to 10 CFR 2.201 requiring information concerning:
- 1) -Corrective action taken and results achieved.
- 2) Corrective steps which will be taken preventing recurrance
- 3) ' Date when full compliance will be achieved 10.CFR 50.72 requires nuclear power reactor licensees to notify the NRC Opera-tions Center within one hour of any accidental radioactive release and of any
- event requiring initiation of any section of the licensee's emergency plan.
Contrary to the above:
"Approximately 3.7E-04 curies of xenon-133 was released when mainten-a.
ance personnel cut in the unisolated side of a waste gas line relief valve and the NRC Operations Center was not notified".
"The licensee's Emergency Plan was implemented during a tornado warning b.
and the NRC Operations Center was not notified".
Discussion:
Toledo Edison agrees with the intent of 10 CFR 50.72 requiring early notifica-tion of dif ficulties within the nuclear power plant and concurs that this is important and necessary to enhance precautionary action or relieving undue
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concern on the part of the public. However, the letter of 10 CFR 50.72 as written, removes any rational, even conservative, judgement on the part of trained and qualified supervisors by requiring that all releases, or any emer-Toledo Edison gency plan initiations he cause for "immediate" notification.
believes that such universal qualifiers as (all) or (any) represent an unman-agable effort on the part of both station operations and the NRC Operations Center, and far exceeds the intest of 10 CFR 50.72. This suggestion was expressed by Mr. T. Murray, Station Superintendent, Davis-Besse Nuclear Power Station, at a Region III meeting and was sympathetically received by M. Keppler, r
Director, who concurred with the logic that a minor laceration, for example, would not be due_cause for notification even though a section of the emergency plan was initiated.- It is our opinion that the same logic is applicable to the xenon-133 release.
Since the area of the release was evacuated quickly, the flow was secured within minutes, and the area was sampled, determining within'one hour that the dose and the curie dontent did not exceed conservative radiological controls, the release was insignificant in regard to the intent of 10 CFR 50.72 and not due j,
cause for notification.
' Relative to the " tornado warning", Toledo Edison believes, here again, that discretion was warranted. In review of events, the dispatcher notified DBNPS of a ~ tornado warning and the Shif t Supervisor notified the Station Superinten-E The Station Superintendent, aware of the confused reporting of the dent.
tornado sighting, and realizing the location of the alledged tornado possed l
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no threat-to DBNPS, did not relate to the Shif t Supervisor a need to notify the NRC Operations Center. Toledo Edison concedes that the Station Superintendent
'i approval is not' required prior to the Shift Supervisor notifying NRC Operations Center-per 10 CFR 50.72.
Our intention here is to relate a lack of emergency and suggest the need for verification prior to notification even though pre-cautionary actions are taken.
In a short time, the tornado' warning was cancelled when actual conditions were assessed, Had the Shift Supervisor notified the NRC when the emergency diesel was started,-an operational precaution but none the less a part of the Emergency Plan,-the red phone would have been manned for starting the diesel - clearly outside the intent of 10 CFR 50.72.
- Toledo Edison believes that we have expressed valid argument justifying a need for discretion when responding to requirements of 10 CFR 50.72 and, currespondingly, anticipate further guidance from the NRC as agreed to by Mr. Keppler. In absence lof the guidelines now pending, Toledo Edison shall evaluate future cases which are subject to the categories of 10 CFR 50.72 to determine thoses cases as signi-ficant events requiring notification.
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Response
- 1) DBNPS Operations management has given and will continue to give verbal reinforcement to written instructions existing with regard to 10 CFR 50.72.
This instruction is to ensure Shift Supervisors are aware of the requirements for prompt notification of the NRC for significant events.
- 2) }bre concise information clarifying the language of 10 CFR 50.72 will be forwarded to DBNPS Operations within Administrative Procedure AD 1839.00, Station Operations, giving better guidance for establishing actions to take in the event of an emergency applicable to 10 CFR 50.72.
- 3) This information will be incorporated upon receipt of NRC guidelines noted within the discussion of this-submittal.
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