ML19345G701
| ML19345G701 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 04/15/1981 |
| From: | Stello V NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Papay L SOUTHERN CALIFORNIA EDISON CO. |
| Shared Package | |
| ML19345G702 | List: |
| References | |
| EA-81-010, EA-81-10, NUDOCS 8104220095 | |
| Download: ML19345G701 (2) | |
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UNITED STATES g
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APR 1 5 1931 Eccket No. 50-206 E4 81-10 y -
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ATTN:
Dr. L. I. Papay, Vice President
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P. O. Box 800 2244 Walnut Grove Avenue 8
Rosemead, California 91770 d
Gentlemen:
This is in reply to your letter of February 17, 1981 which was in response to the Notice of Violation and Notice of Proposed Imposition of Civil Penalties sent to you with our letter of January 23, 1981.
The letter and Notice of l
Violation concerned items of noncompliance associated with steam generator work during the third quarter of 1980 and activities associated with a spent fuel shipping cask on September 5,1980.
We reviewed your r0sponse and found that it contained the information requested in our letter and its attachments.
Each item of noncompliance was admitted and no additional or new information was provided which would modify the items of noncompliance as stated in the Notice of Violation.
Moreover, regarding the exposure of steam generator workers, the information you presented con-firus that (1) a large number of workers were involved; (2) the situation existed for five months; and (3) the event was readily preventable. With respect to the event involving the spent fuel shipping cask, we note "..at information was available to you concerning the particular radiological hazards associated with the spent fuel shipping cask.
Therefore, despite your request to dismiss the civil penalty, we found no acceptable basis to dismiss, mitigate or remit the proposed imposition of civil penalties in the cumulative amount of One Hundred and Fifty Thousand Dollars.
i We acknowledge your strong disagreement with the conclusions contained in our letter which you expressed in paragraph 3, page 6 of Enclosure 2 to your letter.
Our statement that "It is apparent that corrective actions taken to date have not been effective", applied to the period from April - September 1980. We recognize your substantial commitments of resources and actions to improve your radiation protection program since these incidents.
These corrective actions have been successful in controlling the subsequent exposure i
of personnel involved in the steam generator repairs and exemplify the spirit of cooperation Southern California Edison Company has demonstrated over the years.
Had adequate protective measures been taken prior to April during the planning for the extended plant shutdown, the overexposures and, hence, civil I
j penalty action by the NRC could have been avoided.
CERTIFIED MAIL RETURN RECEIPT REQUESTED
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Southern California Edison Company (San Onofre 1)
After careful consideration of your letter dated February 17, 1981, we have determined for the reasons given above and in the enclosed Order concerning the nature of the events, that the items of noncompliance did occur as set forth in the Notice of Violation.
In accordance with the Interim Enforcement Policy which states that one of the goals of the NRC's enforcement policy is to deter " future noncompliance through strong enforcement measures," and considering that no adequate reasons have been shown as to why the penalties for these items should not be imposed, we hereby serve the enclosed Order Imposing Civil Monetary Penalties in the amount of One Hundred and Fifty Thousand Dollars on Southern California Edison Company.
We plan to continue unannounced inspections of your licensed activities. The results of these ir.spections including the implementation of those actions you have taken and plan to take as addressed in your letter of February 17, 1981, will be considered in determining whether further enforcement action is appropriate.
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 enclosure v;ill be placed in the NRC's Public Document Room.
Sincerely, 1
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Victor Ste Jr Director Office of Inspection and Enforcement
Enclosure:
Order Imposing Civil Monetary Penalties 1
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