ML20154A734

Responds to Violation Noted in Activities Under License SOP-2321.Admits to Some Allegations,Including Being Inattentive to Instrumentation & Controls.Denies Accuracy of Each Allegation in Conference W/Util & NRC

ML20154A734
Person / Time
Site:	Peach Bottom, 05502492
Issue date:	09/01/1988
From:	Metz H AFFILIATION NOT ASSIGNED
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
EA-88-080, EA-88-80, NUDOCS 8809130072
Download: ML20154A734 (2)

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Septerrber 1,1988 Director, Office of Enforement US Nuclear Regulatory Ccanission Washington, DC 20555 ATlW: Document Control Desk Ret Reply to a lbtice of Violation Docket No.: 55-2492 Li'.ense No.: SOP-2321 EA88-80 Dear Sir Please accept this letter as ny reply to a notice of violation in cceplianca with 10 cm 2.201. Throughout this proceeding, both in my conference with PEco Security personnel and with NRC Investigators, I had admitted that during the 11:00 p.m. to 7:00 a.m. shift I was, at times, iruttentive to instrumentations and controls and that I allowed w/self and those under my supervision to be distracted by activities such as reading non-job related materials while on dui.y, reclining in a resting position with eyes closed and other activities that precluded adequate performance of licensed duties. During those conferences, however, interviewing personnel referred to ntnercus alleged occurrences. I do not admit to the accuracy of each and every alleged occurrence mentioned ir 9ose conferences. I will continue to stand by tM accuracy of those statt . ..ts that I made during those conferences. During those conferances, I also stated whit I beliove to be the reasons for the violations. 'Ihose reasons include the general nature of shift work, the nunner in wnich shif t work is scheduled, the tronotony of routine job performance, the attitudes of high level administrators, the unavailability of adequate personnel during the midnight shift to permit esployees to have suf ficient breaks during that shif t in order to ranain f resh and alert evi the lack of options available to supervisors in order to discipline e:rployees.

With regard to the other matters required in this reply by Section 2.201(a)(1)(2) and (3), as I Mve retired from my employmnt, I do not feel as though I am in a position to accurately supply such information.

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Director, Office of Enforcement ATIN: Document Control Desk Septenber 1, 1988 Page 2 If further information is required, please so advise. As in the past, it is my intention to cooperate fully in order that all problens associated with this matter can be remedied.

Sincerely yours, I

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Howard L. Metz 1

1 STATE OF MARYLAND, COUtfrY OF HARPOtD, 'IO WIT:

l i I hereby certify that on this 20' day of hpir nh r ,1988, before me, j the subscriber, a Notary Public in and for the County and State aforesaid, i personally appeared HWARD L. METZ, and he made cath in due form of law that i the matters and facts set forth in the aforegoing Reply to a Notice of

Violation are true and correct to the best of his knowledge, information and i belief.

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! AS WIWESS my hand and Notarial Seal.

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My Commission Expires ep g Ub"lVf # - = W I J -- '

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! cc: Regional Administratcr, U. S. Nuclear Regulatory Commission j

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