ML20038C453
| ML20038C453 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 11/23/1981 |
| From: | Thompson D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Utley E CAROLINA POWER & LIGHT CO. |
| References | |
| EA-81-077, EA-81-77, NUDOCS 8112110060 | |
| Download: ML20038C453 (3) | |
Text
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- MC WWS Docket No. 50-324
,gQg License No. OPR-62 EA 81-77 w
y M / Pr ] j N ('es Carolina Power and Light Company ATTN:
E. E. Utley, Executive Vice President k,NO/d7iggpFO y
t Power Supply and Engineering and
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m v,3, ga m.jm Construction A
GM.m M
411 Fayetteville Street
%[Qi Raleigh, NC 27602 ia e
Gentlemen:
In your letter of October 30, 1981, responding to the Notice of Violation and Proposed Imposition of Civil Penalties, enclosed with our letter of October 1, 1981, you requested clarification of Violation C.
Our letter of November 10, 1981, stated that we would respond to your request in a separate letter.
We agree with your position that the radiation protection requirements, estab-lished in a Radiation Work Permit (RWP), for work concerning the Unit 2 reactor water clean-up system valve were prepared by an individual whose qualifications satisfied ANSI N18.1-1971 and the Brunswick technical specifications.
Our review of the RWP and interviews with the personnel involved indicated that the radia-tion control technician who was implementing the RWP was not given specific guidance in the event that radiological conditions changed.
The RWP established protective clothing requirements and specified that health physics coverage was to be provided.
It specifically stated that additional requirements would be "as determined by health physics".
This statement on the RWP implied that the technician was authorized to establish such requirements as were necessary to assure that the work proceeded in a radiologically safe manner.
You assigned a radiation control technician to a job where he was obliged to j
control a potentially hazardous operation.
The technician did not have sufficient experience to exercise the required control and he was not supported by explicit instructions which would have compensated for his inadequate experience.
With respect to the relation of Items A and C in the Notice of Violation, it was incidental that the same individual was involved in both violations.
If this l
inadequately experienced technician had conducted an effective evaluation of the relevant hazards and prevented excessive exposure, you would still have been l
in violation of the technical specification regarding qualifications.
l l
CERTIFIED MAIL RETURN RECEIPT REQUESTED
'ni12110060 00 4
Carolina Power and Light Company 2
In preparing your response you should follow the instructions in the Notice of Violation and Proposed Imposition of Civil Penalties, enclosed with our letter of October 1, 1981.
Your response is requested within thirty days of the date of this letter.
In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice", Part 2, Title 10, Code of Federal Regulations, a copy of this letter will be placed in the NRC Public Document Room.
Sincerely, Original.nigned by Dudley Thompson Dudley Thompson, Director Enforcement and Investigations Office of Inspection and Enforcement cc:
C. R. Dietz, Plc.nt Manager l
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D:EI RHWessman/jh DThompson 11/20/81 11 81 l
NOV Zjl 1981 Carolina Power and Light Company 3-Distribution:
SECY CA VStello, DED/ROGR RDeYoung, IE HDenton, NRR NMoseley, IE 2
JSniezek, IE HThornburg, IE FIngram, PA JMurray, ELD JLieberman, ELD (3)
JCrooks, AEOD JCummings, OIA Enforcement Coordinators, RI, RII, RIII, RIV, RV TBrockett, IE IE Files Central Fi.les CP Book APuglise, CON EDO Reading File l
JHannon, NRR D. Johnson, Resident Inspector Utilities Commission Star Route 1 ATTN:
Mr. Robert Koger Post Office Box 208 Chairman i
Southport, NC 28461 430 N. Salisbury St.
Raleigh, NC 27611 Division of Facility Services ATTN:
Dayne H. Brown, Chief Radiation Protection Section P. O. Box 12200 Raleigh, NC 27605 1
Office.of the Attorney General ATTN:
Hon. Rufus L. Edmisten Attorney General l
Justice Building P. O. Box 629 Raleigh, NC 27602 i
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