ML20011D605

Responds to NRC 891115 Ltr Re Violations Noted in Insp Repts 50-334/89-18 & 50-412/89-18.Corrective Actions:Use of Overtime for Plant Personnel & Operators Reviewed & New Schedule Evenly Distributing Overtime Developed

ML20011D605
Person / Time
Site:	Beaver Valley
Issue date:	12/15/1989
From:	Sieber J DUQUESNE LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 8912280085
Download: ML20011D605 (4)

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L,; aver whey Power Station

. Shippirgport, PA 15077 0004 i

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• 64 M 5 December 15, 1989 l I

U. S. Nuclear Regulatory Commission 1 Attn: Document Control Desk l Washington, DC 20555 j

Reference:

Beaver Valley Power Station, Unit No. 1 and No. 2 y BV-1 Docket No. 50-334, License No. DPR-66 i BV-2 Docket No. 50-412, License No. NPF-73 Combined Inspection Report 50-334/89-18 and 50-412/89-18 Gentlemen:

In response to NRC correspondence dated November 15, 1989 and in accordance with 10 CFR 2.201,.the attached reply addresses the Notice of Violation included with the referenced inspection report.

We share your concern regarding the identified weakness in '

management control of overtime use. .I have issued-a letter to Station Management personnel to emphasize the need to comply with company overtime policies. I have also established requirements to monitor and report violations-of the overtime policies to myself and the unit managers.

If' there are any questions concerning this response, please- l contact my office.

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-Very truly yours, l l

h D. Sieber j.

i t UVice President Nuclear Group Attachment cc: Mr. C. Beall, Sr. Resident Inspector Mr. W. T. Russell, NRC Region I Administrator Mr. Edward C. Wenzinger, Chief Reactor Projects Branch No. 4, Division of Reactor Projects, Region I Mr. R. Saunders (VEPCO) 8912280085 841215 l PDR ADOCK 05000334 M- PGS) _. _ _ _ _ _ _

DUQUESNE LIGHT COMPANY Nuclear Group Beaver Valley Power Station Units 1 and 2 red 1v to Notice of Violation Combined Inspection Report 50-334/89-18 and 50-412/89-18 Letter Dated November 15, 1989 VIOLATION A (Severity Level IV, Supplement I)

Descriotion of Violation (50-412/89-18-02)

Unit 2 Technical Specification 6.2.2.f.b requires that certain personnel including reactor operators not work more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in any seven day period, excluding shift turnover time, unless authorized by the plant manager or his designated alternate.

Contrary to the above, during the periods given below, three reactor operators worked more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in a seven day period 1 without authorization:

March 18, 1989 to March 24, 1989 - Two operators exceeded-  !

the requirement.

May 5, 1989 to 'May 11, 1989 - One operator exceeded'the requirement.

Corrective Action Taken j We have conducted a review of working hours.in excess of the guidelines of our Nuclear- Group Directive 19, "Use ot (NGD) i Overtime", for plant personnel, including determined that there were no adverse affects on work performed all operators. .-It was  !

relative to the above three cases and no safety related work was '

performed without review and/or double-verification by personnel not exceeding NGD 19 guidelines. Although scheduling for supervisors, licensed operators and non-licensed operators was prepared in advance to- avoid excessive overtime,. individual  ;

overtime accounting was found to be. complicated and inadequate.

The Operations Administrative Assistants responsible for scheduling overtime lacked consistency in -accounting methods,:

missed entries, had incomplete or inadequate entries and did not' 1 fully understand- the requirements of NGD 19 while scheduling {

j overtime.

continuity Foremen allotted operators additional overtime.for job  !

or holdovers without adequately researching eligibility based on- NGD. 19 and/or without conferring with the-  ;

i Administrative Assistant.

A review of NGD 19 guidelines was required for all Operations -

supervisors and the Administrative Assistants performing scheduling. These personnel have been notified that further violations will not be tolerated.

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R: ply'to Notics of Violation (continutd) 4 Action Taken to Prevent Recurrence A new _ schedule, which more evenly distributes the required ,

overtime between the operators, has been developed- and" implemented for use during the Unit i refueling outage. The use of this new outage schedule simplifies the tracking of overtime worked, because scheduled ' overtime is included with the basic outage work schedule. With current information, the Administrative Assistant is able to review the affects of changes on an individual's present overtime eligibility and- record changes for future- reference. Any hours to be' worked, in addition to the hours already scheduled, are then analyzed for potential violations of NGD 19. These methods have proven to be effective in preventing reoccurrence of the problem during-the Unit 1 outage. A monitoring program to assure compliance with NGD 19 requirements has been established and incorporated into '

NGD 19.

Action to correct Weakness ,

The Vice President Nuclear issued a letter dated November 30, 1989 to station management personnel, which emphasized the need to comply with the company overtime policies and' provided additional guidance to_ improve management control over-the use of overtime. Requirements were established to monitor violations of overtime restrictions and report them to senior management for proper oversight.

Date When Full Comoliance vill be Achieved l The station is in compliance at this time.

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'VI LATION B (Geverity Level IV, Supplement I)

Descriotion of Violation (50-412/89-18-01)

Unit 2 Technical Specification 4.7.1.2.a.l.4 requires - that constant- communications be maintained between the control-room and the auxiliary feed pump room while-any normal discharge valve is closed during surveillance testing.

Contrary to the above, on _ October 5, 1989, constant communications between the ;ontrol room and the auxiliary feed i pump room were not maintained while the normal discharge valve to the steam dliven auxiliary feed pump was shtt during surveillance testing.

Corrective Action Taken  !

Communications had been established with-the Control Room-using the "Gaitrenics" page party system -in accordance with surveillance procedures, with the operator keeping the handset to his ear. Despite' the caution in the procedure to maintain constant communications, the . local operator broke communication temporarily to perform pump inspections and returned to his_ post ,

approximately three minutes later and reestablished (resumed) the direct communications link with the Control Room Plant Operator via the page party system. ; Interviews were conducted with all Operations personnel involved. A report was prepared and the information reviewed with all' involved to stress the significance '

of the event and adherence to procedures.

Action Taken to Prevent Recurrence Operations Surveillance Tests 2.24.2, 3 and 4Lfor-the electric-and steam driven auxiliary feedi water- pumps _were reviewed.

Adequate caution exists in each procedure to maintain constant communications during pump testing when_ the_ normal discharge i valve is closed but does not specify the method.to be-used. :To avoid similar problems in the future, the caution _ini thel procedures was revised to- use headsets- for constant communication.

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Operations personnel will-be made aware of this clarification thru required reading training _ stressing procedure compliance and the basis for constant communication.- '

Date When Full Compliance will be Achieved The station is in compliance at this time.

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