ML19269E064
| ML19269E064 | |
| Person / Time | |
|---|---|
| Site: | Kewaunee  |
| Issue date: | 05/03/1979 |
| From: | Lieberman J NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Smith I Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 7906230165 | |
| Download: ML19269E064 (5) | |
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Honorable Ivan W. Smith Administrative Law Judge M
Atomic Safety and Licensing Board
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Washington, D. C. 20555 In the Matter of Wisconsin Public Service Corporation License flo. DPR-43
Dear Judge Sm1th:
0 Enclosed are the flotice of Appearances for the Staff in this pro-ceeding.
The documents referenced in the May 1,1979, flotice of Hearing are also enclosed.
These documents were elther sent to the Wisconsin Public Service Corporation or were originated by them.
The Staff expects to offer some or all of these referenced documents into the evidentiary record of this proceeding.
Respectfully submitted, 1
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A J imes Lieberman Junsel for flRC Staff
Enclosures:
(1) flotices of Appearances of Messrs. Burnt, lieberman and Murray (2) 3/15/79 Request for Hearing 2250 36 (3) Order Imposing Civil Penalties, 2/22/79, including - Appendix I, Amended flotice of Violation & Amended flotice of Proposed Impositions of Civil Penal ties,12/7/78 Appendix II 1/2/79, Answer of Licensee.c the 12/7/78 flotices (Continued) 700623 0/fK
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I Judge Ivan W. Smith May 3,1979
Enclosures:
(Continued)
(4) Notice of Violation and Notice of Proposed Imposition of Civil Penalties, 7/19/78 (5) 8/10/78 Answer to Licensee to the i
7/19/78 Notices cc: Steven E. Keane, Esq.
Docketing & Service Section 6
I U!IITED STATES OF A!iERICA NUCLEAR REGULATORY C0tC4ISSI0ti
'BEFORE'THE ADMINISTRATIVE LAN JUDGE _
In the liatter of Docket tio. 50-305 License No. DPR-43 WISC0tlSIN PUBLIC SERVICE CORPORATION )
(Kewaunee fluclear Power Plant)
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NOTICE OF APPEARANCE tiotice is hereby given that the undersigned attorney herewith enters In accordance with an appearance in the above-captioned matter.CFR Part 2, the following info 6 2.713, 10
- Stephen G. Burns Name U. S. Nuclear Regulatory Commission Address Office of Executive Legal Director i
Washington, D. C. 20555 Telephone ilumber (301)492-7496 District of Columbia Admission Court of Appeals Name of Party
- NRC Staff U. S. Nuclear Regulatory Commission Washington, D. C. 20555 r,0 p%2n n huttj
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' Stephen G. Burns Counsel for NRC Staff Dated at Bethesda, Maryland this 3rd day of May,1919 2250 338 I
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e UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ADMINISTRATIVE LAW JUDGE In the Matter of
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Docket No. 50-305 WISCONSIN PUBLIC SERVICE CORPORATION)
License No. DPR-43 (KewauneeNuclearPowerPlant)
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NOTICE OF APPEARANCE Notice is herchy given that the undersigned attorney herewith enters In accordance with an appearahce in the above-captioned matter.
S 2.713, 10 CFR Part 2, tae following infonnation is provided:
Name
- James Liebennan Address U. S. Nuclear Regulatory Commission Office of Executive Legal Director Washington, D. C. 20555 Telephone Number (301) 492-7496 Admission
- Supreme Court of Virginia Name of Party
- NRC Staff U. S. Nuclear Regulatory Commission Washington, D. C. 20555 i
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James Liebennan Counsel for NRC Staff Dated at Bethesda, Maryland this 3rd day of May, 1979 2250 339
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COM'4ISSION BEFORE THE ADMINISTRATIVE' LAW JUDGE-
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In the Matter of l
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Docket No. 50-305
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License No. DPR-43 l
WISCONSIN PUBLIC SERVICE CORPORATION
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i (Kewaunee fluclear Power Plant) i NOTICE OF APPEARANCE _
i Notice is hereby given that the undersigned attorney herewith enters In accordance with an appearance in the above-captioned matter.CFR Part 2, the followin i
S 2.713, 10 Name James P. Murray i
Director and Chief Counsel Rulemaking and Enforcement Division Address i
Office of Executive Legal Director U. S. Nuclear Regulatory Commission 1
Washington, D. C. 20555 (301) 492-7496 Telephone Number l
Supreme Court of the United States Admissions U. S. Court of Appeals for the District of Columbia NRC Staff i
Name of Party U. S. Nuclear Regulatory Commission Washington, D. C. 20555 j
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[}jJames P. Murray
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Director and Chief Counsel Rulemaking and Enforcement Division Dated at Bethesda, Maryland this 3rd day of May,1979 2250 340
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, WISCONSIN P U B LIC S E RVIC E C O R PO R ATI O N Q~ ?g P.O. Box 1200, Green Boy, Wisconsin 54305 CERTIFIED MAIL RETURN RECEIPT REQUESTED March 15,1979 Mr. John G. Davis Acting Director Of fice of Inspection and Enforcement U. S. Nuclear Regulatory Commission Washington, D. C.
20555
Dear Mr. Davis:
On Feb rua ry 2 2, 1979, your office issued an Order Imposing Civil Penalties against Wisconsin Public Service Corporation, operators of the Kewaunce Nuclear Power Plant, in regard to an incident which occurred on May 2, 1978.
Our responses referenced in the Order included specific points of clarifica-tions in regard to the Fby 2, 1978, event which were absent f rom the NRC inspection findings.
Those clarifications cast sighificant doubt as to the accuracy of the NRC evaluation of the events of May 2,1978.
We also noted th at the criteria for civil penalties issued by the NRC in December of 1974 does not address events such as the May 2,1978, event and had requested clarification from your of fice as to the specific criteria considered applicable to these mat te rs.
Because we disagree with the NRC's evaluation of the cause of the event; because the NRC's investigation which led to the NRC conclusions incomplete; because the NRC's interpretation of our procedures is/was in was error; because the NRC has not been able to identify the specific section of its ovi criteria for imposition of civil penalties which apply to the May 2, 1978, event; because the IE Circular 76-03 which was provided to licensees was inconplete and lacked detailed radiation field variation data known to the NRC; and because the actions constituting the Fby 2,1978, event were taken on the basis of assuring safety of personnel and the plant; we hereby request a hearing on this matter pursuant to 10 CFR 2.205(d).
Our Attorneys are filing under separate cover a formal request for the same.
Sincerely, 2250 341 C
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!!UCLEAR TIGULATORY COF_nbbluN (g:
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Wisconsin Public Service
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Docket No. 50-305 Corporation,
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Wisconsin Power and Light
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License No. DPR-43
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- Company, Madison Gas and Electric'
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REQUEST FOR HEARING e
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Pursuant to the rules promulgated by the Nuclear Regulatory Cournission, 10 C.F.R. 52.205(d) the above named Licensees hereby request a hearing to review the " Order Imposing Civil Penalties" dated February 16, 1979 sent to Licensees under cover letter l
dated February 22, 1979 of John G.
Davis, Acting Director, Office of Inspection and Enforcement.
I Dated this /6MdayofMarch,1979.
Steven E. Keane David A. Baker w
By Attorneys for Licensees OF COUNSEL FOLEY & LARDNER D
777 East Wisconsin Avenue Milwaukee, Wisconsin 53202
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I Docket No. 50-305 Wisconsin Public Service i
l Corporation ATTN:
Mr. P. Ziemer Pres i~d en t -
Post Office Box 1200 j
Green Bay, WI' 54305 Gentl emen:
i This is in response to your letter dated January 2,1979, which _was in response to the Amended Notice of Violation and Amended Notice of.
I Proposed Imposition of Civil Penalties sent to you with our letter dated December 7,1978.
l The December 7,1978 letter concerned two items of noncompliance found during a Nuclear Regulatory Commission inspection on May 3-5 and 18, and June 5,1978, o.f the radiation protection program at your Kewaunee Nuclear Pcwer Plant.
i Af ter careful consideration of your January 2,1979 response, we conclude that the items-of noncompliance did occur as described in the Amended Notice of Violation.
With regard to item 1, we find no evidence that i
continuous escort by e~xperienced health physic personnel was provided nor was the purpose of the procedure fulfilled.
With regard to item 2, you have admitted noncompliance.
Accordingly, we hereby serve the er. closed Order en Wisconsin Public Service Corporation, imposing Civil Penalties in the amount of Seven Thousand Dollars (57,000).
The two items of noncompliance were related to an incident involving entry into the reactor _ cavity, an area with the potential for causing a
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substantial radiation overexposure.
The potential was brought to your attention through IE Circular 76-03, " Radiation Exposures in Reactor Cavities," which was acknowledged by you on November 12, 1976.
Both items of noncompliance contributed to the seriousness of the incident, which had t.he potential for causing a substantial radiation overexpo-The imposition of Civil Penalties in this case is consistent sure.
with enforcement policy and published criteria.
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&I RETURN -RR[]FT REQUESTED
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We will review your corrective. actions regarding the items of noncompliance during future inspections.
Sincerely, i
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John G. Davis i
Acting Director Office of Inspection t
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NUCLEAR REGULATORY COMMISSION In the Matter of
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Docket No. 50-305
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License No. DPR-43 Wisconsin Public Service
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Green Bay, WI 54305
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ORDER IMPOSING CIVIL PENALTIES
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Wisconsin Public Service Corporation, Green Bay, Wisconsin, (the " licensee"),
l is the holder of License No. DPR-43 (the " license"), issued by the Nuclear Regulatory Commission (the " Commission"), which authorizes the licensee to I
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operate the Kewaunee Nuclear Power Plant located in Kewaunee County, Wisconsin, in accordance with the conditions specified therein.
The license was issued on December 21, 1973, and has a termination date of August 6, 2008.
II
. A special inspec' tion of cer 'ain of the licensee's activities ender the license was conducted on May 3-5,18 and June 5,1978.
As a result of this inspection, it appears that the licensee has not conduc.ted its activities in full compliance with the requirements of the Technical
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A written Notice of Violation and Notice of Proposed Specifications.
Imposition.of Civil Penalties in the amount of $10,000 was served upon the licensee by letter dated July 19,1978 (incorrectly dated June 19, 1978).
The licensee responded,
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.o Wisconsin Public Service Corporation
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ATTN:
fir. P. Ziemer President Post Office Box 1200 Green Bay, Wisconsin 54305 Gentlemen:
This refers to your letter of August 10, 1978, which responded to the flotice of Violation and flotice of Proposed Imposition of Civil Penalties sent to you with car letter of July 19,1978 (incorrectly dated June 19, 1978).
Our July 19, 1978 letter identified apparent items of noncom-pliance found during our inspection conducted on fiay 3-5,18, and l
June 5,1978, at your Kewaunee fluclear' Power Plant.
3 After careful consideration of your August 10, 1978 letter to Dr. Volgenau and the letters of July 20, 1978 and August 15, 1978, from i
fir. E. W. James to fir. James G. Keppler, we are amending the fictice of l
Violation and Notice of Proposed Imposition of -Civil Penalties sent to you on July 19, 1978, for the reasons given in Appendix C to this letter.
i The effect of this change is the reduction of the cumulative amount of civil pent.lties from Ten Thousand Dollars ($10,000) to Seven Thousand Dollars ($7,000).
We are concerned with positions taken in your responses to the liay 2 incident.
Specifically you: 1) minimize the significance of the incident, 2) appear to condone token efforts to follow procedures, and
- 3) fail to acknowledge management's responsibility for licensed activi-ties at the Kewaunee plant.
You appear to minimize the significance of the fiay 2 incident in'the final paragraph of your Answer to Notice, which states that "...no safety threat or actual danger was created by the event...".
We would emphasize the fact that entry into radiation fields of 2000 R/hr allows an individual to receive a dose at the-rate of over 0.5 rems per second.
Less than six (6) seconds exposure at this rate would have resulted in a dose that exceeds the regulatory limit.
We regard the lack of a signifi-cant overexposure in the liay 2 incident to be simply fortuitous..
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You appear to condone token e -
procedures.
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...a survey of the afea (as in fact performed." However, DUPLICATE DOCUMENT CERTIFIED P. AIL Entire document previously liEluRN RCTiPT RE0' JESTED entered into system under:
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p:U P.O. Box 1200, Green Bay, Wisconsin 54305 January 2, 1979 Mr. John G. Davis Acting Director Of fice of Inspection and Enforcement U. S. Nuclear Regulatory Commission Washington, D. C.
20555
Dear Sir:
This letter and the two attachments (Response to Amended Notice of Violation, Appendix A, and Answer to Amended Notice of Proposed Imposition of Civil Penalties, Appendix B) respond to your letter of December 7; 1978, and its attachments.
As you will note f rom the attachments, we continue to take exception to your position which, in error, continues to refer to the action of our Shift Supervisor as a non-compliance with our procedure RC-HP-35.
As the attach-men ts indicate, we cannot see that that incident was other than that the H-P technician did not survey the area completely and our Shift Supervisor assumed that when he requested the survey, he was receiving adequate informa-tion.
Certainly when he was told he would be entering a 75 rem field he knew that he was entering a high radiation area and planned to meet that condition.
It bothers us greatly that this condition is then characterized by you as a significant :ranagement weakness.
We feel we have acted very responsibly in '
putting together a strong management team at the Kewa unee Plant.
We have supplied the Health Physics Department with the very best of instrumentation.
Other nuclear plants have contacted us at the urging of your own inspectors to inquire about progran.s your inspectors told them were very good at Kewaunee.
Even before this incident occurred, we had originated the Design Change No. 746 project which will put radiation monitors in six areas with potential for significant radiation level changes.
These meters will have remote read-out from outside the monitored areas.
The Reactor Cavity Area is one of those areas for which instrumen ts are on order.
7 In the Operating Budget for January 1 money for additions to our Health Phy<
on a shi ft basis around the clock.
T1 DUPLICATE DOCUMENT and trained in an extensive training I Entire document previously entered into system under:
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Of CERTIFIED MAIL RETURN RECEIPT REQUESTED ANO //
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Wisconsin Public Service Corporation Docket No. 50-305 ATIN:
Mr. P. Ziemer i
l President l
Post Office Box 1200 Green Bay, Wisconsin 54305 Gentlemen:
I The findings of a recent inspection of the radiation protection program at the Kewaunee Nuclear Power Plant, particularly with regard to the t
personnel exposure which occurred in the reactor cavity on Msy 2,1978, indicate a significant management weakness related to radiation protec-tion.
The inspection findings have been discussed with members of your staff by telephone on several occasions since the inspection.
More importantly, the Director of our Region III Office met with ycu on May 18, 1978 to discuss the circumstances surrcundinn the May 2 exposure.
At that meeting we also discussed the three ",,,orent items of noncompliaace found during the recent inspection.
These noncompliances are set forth in the Notice of Violation attached as Appendix A to this letter.
In our view, the items of noncompliance in Appendix A demonstrate a lack of effective radiation exposure control.
The potential for a significant personnel exposure in the reactor cavity was described in IE Circular No. 76-03, " Radiation Exposures in Reactor Cavities," dated September 10, 1976.
In your November 12, 1976 response to this circular, you described the controls in effect at tne Kewaunee facility to prevent such an exposure.
The incident apparently resulted from a breakdown of these controls.
While the actual exposure of 2.9 rems did not exceed the regulatory limit, we consider the May 2 exposure to be very serious because of the potential for an extremely large radiation exposure.
Our concern is even greater because our inspection showed that the decision to enter CERTIFIED MAIL D
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the reactor cavity was made by the senior member of management present on site with disregard for the survey required by the regulations, e
without the Radiation Work Permit required by your procedures, and without the radiation monitoring device required by your Technical Specifications.
Consequently, we propose to impose civil penalties in the cumulative amount of Ten Thousand Dollars ($10,000) for these l
noncompliances.
Appendix B of this letter is the Notice of Proposed Imposition of Civil Penalties.
You are required to respond to this i
letter, and in preparing your response you should follow the instruction in Appendix A.
As noted previously, the employee who decided to enter the reactor cavity and who was subsequently exposed, was the senior Wisconsin Public Service Corporation employee on site at the time.
Recognizing the natural tendency of other employees to refrain from stopping activities initiated by such an individual, the importance of supervisors' adherence to established requirements cannot be overstated.
Inadequate communica-
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tion between those involved also appears to have been a major contributor to the incident.
In responding to the noncompliance items in Appendix A, you should specifically address your plans for strengthening these i
a reas.
I would also like to address another concern.
At about 8:30 a.m. on flay 3,1978, upon arrival at the Kewaunee fluclear Power Station to inspect certain refueling outage activities, our inspectors were informed that a potential radiation overexposure had occurred at about 2:30 a.m. on May 2,1978.
Although aware soon after the incident that a substantial overexposure might have occurred, plant personnel had not informed our assigned project inspector who was present at the plant on flay 2.
While notification was not required since the exposure did not exceed regulatory limits, we are concerned that we were not promptly informed of this matter in view of our evident interest and the presence on site of our project inspector on the day of the occurrence.
We hope that you will freely inform us of any potential problem where the f1RC has a legitimate interest.
Your written reply to this letter and flotice of Violation and the findings of our continuing inspections of your activities will be considered in determining whether further enforcement action, such as additional civil penalties or orders to suspend, modify or revoke the license, may be required to assure future compliance.
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'.i In accordance'with Section 2.790 of the NRC's " Rules of Practice,"
Part 2, Title 10, Code of Federal Regulations, a copy of this letter and the enclosures will be placed in the NRC's Public Document Room.
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Sincerely,
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l Ernst Volgenau Director
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Office of Inspection and Enforcement I
Enclosures:
1.
Appendix A, Notice of Violation 2.
Appendix B, Notice of Proposed Impositi6n of Civil Penalties 4
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Jtf7 19 1978
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HOTICE OF VIOLATION l
l This refers to the inspection conducted by representatives of the F
Region III (Chicago) Office at the Kewaunee Nuclear Power Plant, Kewaunee, Wisconsin, of activities authorized by NRC License No. DPR-43.
During this inspection conducted on flay 3-5, 18 and June 5, 1978, the following apparent items of noncompliance were identified.
I 1.
10 CFR 20.201, " Surveys," requires in section (b) that each licensee make or cause to be made such surveys as may be necessary for him to comply with the regulations of 10 CFR 20.
As defined in i
10 CFR 20.201, section (a) " Survey" means an evaluation of the radiation hazards incident to the production, use, release, dis-posal, or presence of radioactive materials or other sources of radiation under a specific set of conditions.
Contrary to the above, you failed to make such surveys as were necessary to assure compliance with 10 CFR 20.101, " Exposure to Individuals to Radiation in Restricted Areas."
Specifically, you failed to make such a survey to assure that dose limits would not be exceeded on May 2, 1978 when an employee entered the reactor cavity and moved about in general radiation fields later measured to be as high as 2000 R/hr.
This violation had the potential for causing a substantial radiation overexposure.
(Civil Penalty - $4,000) 2.
Technical Specification 6.11, " Radiation Protection Program" requires that procedures for personnel radiation protection shall be prepared consistent with the requirements of 10 CFR. Part 20, and shall be approved, maintained and adhered to for all operations involving personnel radiation exposure.
Procedure RC-HP-35, Revision B, dated April 15,1976, " Radiation Work Permit," states in section 1.1 that the purpose of a Radiation Work Permit (RUP) is to protect plant personnel by controlling access into areas such as high radiation areas, requires in section 2.1.1 that a RWP be issued for entry into any high radiation area, and specifies in section 6.0 the tasks which must be performed by various personnel prior to approval and issuance of the RWP.
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- Contrary to the above, on May 2,1978 a Radiation Work Permit was not approved and issued to control access into a high radiation area prior to an employee entering the reactor cavity where he moved about in general radiation fields later measured to be as i
l high as 2000 R/hr.
f This is an infraction.
(Civil Penalty - $3,000)
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3.
Technical Specification 6.13.1 requires that any individual or group of individuals permitted to enter a high radiation area shall be provided with a radiation monitoring device which continuously indicates the radiation dose rate in the area.
Contrary to the above, on May 2,1978, a radiation monitoring device which continuously indicates the radiation dose rate was not provided to an employee who entered the reactor cavity, a high radiation area containing general radiation fields later measured to be as high as 2000 R/hr.
This is an infraction.
(Civil Penalty - $3,000)
This notice of violation is sent to you pursuant to the provisions of Section 2.201. of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations.
You are hereby required to submit to this office, within twenty (20) days of your receipt of this notice, a written statement or explanation in reply, including for each item of noncompliance:
(1) admission or denial of the alleged items of noncompliance; (2) the reasons for the items of noncompliance, if admitted; (3) the corrective steps which have been taken by you and the results achieved; (4) corrective steps which will be taken to l
avoid further noncompliance; and (5) the date when full compliance will be achieved.
2250 352 4
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- fN 19 1378 Appendix B NOTICE OF PROPOSED IMPOSITION OF CIVIL PEiulTIES Visconsin Public Service Corporation Docket No. 50-305 l
This Office has considered the enforcement options available to the i
NRC, including administrative actions in the form of written notices of violation, civil monetary penalties, and orders pertaining to the modification, suspension, or revocation of a license.
Based on these i
considerations we propose to impose civil penalties pursuant to Section 234 of the Atomic Energy Act of 1954, as amended (42 USC 2282), and to 10 CFR 2.205, in the cumulative amount of Ten Thousand Dollars ($10,000) l for the specific items of noncompliance set forth in Appendix A to the cover letter.
In proposing to impose civil penalties pursuant to this section of the Act and in fixing the proposed amount of the penalties, the factors.identifed in the statements of consideration published in the Federal Register with the rule making action which adopted 10 CFR i
2.205 (36 FR 16894) August 26, 1971 and the " Criteria for Determining Enforcement Action," which was sent to NRC licensees on December 31, 1974, have been taken into account.
Wisconsin Public Service Corporation may, within twenty (20) days of the date of receipt of this notice, pay the total civil penalties in the cumulative amount of Ten Thousand Dollars ($10,000) or may protest the imposition of the civil penalties in whole or in part by a written answer.
Should Wisconsin Public Service Corporation fail to answer within the time specified, this office will issue an order imposing the civil penalties' in the amount proposed above.
Should Hisconsin Public Service Corporation elect to file an answer protesting the civil penalties, such answer may (a) deny the items of noncompliance listed in the Notice of Violation in whole or in part, (b) demonstrate extenuating circumstances, (c) show error in the Notice of Violation, or (d) show other reasons why the penalties should not be imposed.
In addition to protesting the civil penalites in whole or in part, such answer may request remission or mitigation of the penalties.
Any written answer in accordance with 10 CFR 2.205 should be set forth separately from your statement or explanation in reply pursuant to 10 CFR 2.201, but you may incorporate by specific reference (e.g., giving page and paragraph numbers) to avoid repetition.
Wisconsin Public Service Corporation's attention is directed to the other provisions of 10 CFR 2.205 regarding, in particular: failure to answer and ensuing orders; answer, consideration by this office, and orders; requests for hearings, hearings, and ensuing orders; compromise; and collection, c
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'-.:n Upon failure to pay any civil penalty due which has been subsequently determined in accordance with the applicable provisions of 10 CFR 2.205,
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the matter may be referred to the Attorney General, and the penalty, unless compromised, remitted, or mitigated, may be collected by civil i
action pursuant to Section 234c of the Atomic Energy Act of 1954, as amended, (42 USC 2282).
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P.O. Box 1200, Green Boy, Wisconsin 54305 August 10, 1978 Mr. Ernest Volgenau, Director Of fice of Inspection and Enforcement U. S. Nuclear Regulatory Commission Washington, D. C.
20555
Dear Sir:
Wisconsin Public Service Corporation (Kewaunce Nuclear Plant) Docket No. 50-305 July 19, 1978 Notice of Violation This written explanation is provided pursuant to the requirements of 10 CFR H 2.201 in response to your letter of July 19,1978 (apparently erroneously dated June 19, 1978) which transmitted a Notice of Violation and Imposition of Civil Penalties related to an event at the Kewaunce Nuclear Power Plant on May 2, 1978.
As to Item 1, Wisconsin Public Service Corporation (hereinaf ter "WPSC")
denies the allegation of the violation.
As to Item 2, WPSC also denies the allegation of an infraction.
As to Item 3, UPSC admits an infraction subject to the explanation set forth below (See also the attached Answer to Notice.).
The following is WPSC's description and evaluation of the May 2, 1978, event.
On the morning of May 2,1978, the filling operation of the refueling pool '
was interrupted with a water level of approximately 8" above the reactor vessel flange to perform an inspection.
An operator was dispatched to inspect for Icaks. That inspection indicated significant leakage about either the reactor vessel-refueling pool seal or the sand plug covers over the reactor vessel nozzles.
When this information was supplied to the Shift Supervisor, he decided to enter the containment area so as to be abic to evaluate the nature and extent of the problem and to determine what corrective measures were. indicated.
The Shift Supervisor, in concurrence with the Night Refueling Coordinator, determined the most direct way to e the leakage source and the extent of leakage, which appeared large, CERTIFIED MAIL RETURN RECEIPT REQUESTED Entire document previously entered into system under:
No. of pages:
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i UNITED STATES NUCLEAR REGULATORY COMMISSION
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l Wisconsin Public Service Corporation
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j
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ANSWER TO NOTICE OF j
(Kewaunee Nuclear Power Plant)
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0F VIOLATION AND
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PROPOSED IMPOSITION
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0F CIVIL PENALTIES I
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Docket No. 50-305
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Pursuant to 10 C.F.R. S 2.205 and in answer to the Notice of Violation, Wisconsin Public Service Corporation (herewith "WPSC"),
by its undersigned attorneys admits, denies and states as follows:
1.
It is alleged that WPSC failed to make a survey required to assure compliance with 10 C.F.R.
S 20.101, Section 20.101(b)(1) provides:
"During any calendar quarter the dose to the whole body from radioactive material and other sources of radiation in the licensee's possession shall not exceed 3 rems.
At no time during the event in question was this limit exceeded.
As acknowledged by WPSC and NRC exposure to the individual was about 2.90 rem. (See I E Inspection Report No. 50-305/78-07, page 9.)
2250 356 The statement that there was a failure to survey is simply factually inaccurate.
Prior to making his entry to the reactor vessel cavity, the shift supervisor reg clarification of the safety requi DUPLICATE DOCUMENT result of that request, a survey Entire document previously entered into system under:
M, h,,,.b applicable regulations) was in fr ANo a, (
accurately to disclose the actua No. of pages:
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