ML20058G143

Responds to Violations Noted in Insp Repts 50-327/90-22 & 50-328/90-22.Corrective Actions:Procedures Governing Use of Overtime Revised

ML20058G143
Person / Time
Site:	Sequoyah
Issue date:	11/06/1990
From:	Medford M TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9011090419
Download: ML20058G143 (4)

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TENNESSEE VALLEYL AUTHORITY!.

CH ATTANOOGA. TENNESSEE ' 374ol, j

6N 38A Lookout' Place i

NOV:061990 I

U.S. Nuclear Regulatory Commission ATTN: Document Control' Desk j

Washington; D.C.

20555 j

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In the Matter of

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' Docket Nos. 50-327 L!

Tennessee Valley Authority

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!S0-328:

1 SEQUOYAH NUCLEAR PLANT (SQN) - NOTICE OF VIOLATION-(NOV) 50-327,:328/90-22-01

- OVERTIME CONTROL As a result of quality assurance (QA) monitoring activities. conunitted to and descrit d in TVA's initial response to the subject NOV,.TVA has' determined that some problems still exist with nanaging and controlling the use of overtime'and that the implementation of' Site OvertimelProcedure. SSP-32.53,.

" Administration of.0vertime,'" must be reinforced.

In response to the July 26,.1990, overtime violation',, 50-327, 328/90-22-01, the following corrective actions were taken:'

The procedures governing the use of overtime.were revised..

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Meetihgs with management and employens were held to ensure' site' personnel.

were aware of management's expectations:and the regulatory requirements..

Individual organizations evaluated the adequacy of their!internalf i

processes for controlling and approving use of overtime. 'Also, these organizations reviewed'their control processes.and-practices to identify.

areas needing improvement.

To ensure.the effectiveness of.the corrective actions,.QA wasocharged i with performing monitoring activities. associated with the. implementation of the procedure requirements during;and after-'the Unit 2l Cycle 4 (U204).

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refueling outage.

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Independent of these activities, it was also verified th'atLthe. current plant-staffing level:at SQN is consistent with and in cases'above the' average-staffing level at a-comparable two-unit. pressurized water. reactor plant..

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As a result of: management's review. of 'recent QA monitoring: activities, it.has been determined that the above corrective.actionsJhavelnot been totally.

effective in all areas.

Specifically,Ldeficiencie's hav'eLbeen identified in the documentation of the basis for and approval of overtime usageLin excess.of the limits specified in Generic Letter 82-12, " Nuclear: Power Plant Staff' a

9011090419 901106 i '

PDR ADOCK 05000327 4 **-

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-l An Equal Opportunity Employe/.

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U.S. Nuclear Regulatory Commission NOV 061990 J

Working Hours," and TVA-procedures. Areas for further' improvement in-procedures and control processes have also been identified.

In addition, the-administration of overtime in some cases is constrained as a result of the current general agreement with the-unions, j

Despite these problems, improvements in controlling the-use of overtime have been noted. During the_first seven weeks of the U204 refueling outage, 29,000 i

fewer overtime hours were expended' than for Unit 1.

This was' accomplished l

even with an outage. scope increase over Unit 1,.NRC operator requalificationi j

exams, two Unit l' reactor trips,' and a subsequent Unit 1 foteed shutdown, j

which required extensive manpower to support the associated corrective; actions

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and start-up activities.

In response to the more recently identified areas-needing improvements, the following additional: actions are beingltaken to further strengthen controls

_i and ensure compliance-with the requirements:--

The supervisors responsible for_ obtaining' approvals for authorization of.

an employee to work in excess of the overtime-guidelines and did.not-comply with the program requirements'will_ receive-appropriate 1 disciplinary action.

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A memorandum, along with face-to-face discussions to ensure i

understanding,-will be issued to the duty plant-managers stating that l

procedural adherence must be observed to ensure the overtime limitation-exception report is completed properly'before appro' val can be1given.

Increased controls on preapproved-overtime up to and including Site Vice-President approval.will be established.

The Plant Manager'has issued a letter to his' direct reports that no employee shall exceed 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />s:in~a 7-day period without his approval.

(The duty plant manager can only approve the useLof~ overtime in excess of' i

16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> in a 24-hour period and 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />s:in'a 48-hour period.)

A review of the' overtime procedure and form is being conducted to determine if the form can be made user friendly and if better guidance can.be provided in completing _the form. The procedure will-be, revised to disallow " blanket" approvals.1

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TVA will obtain a computerized process to aid supervisors'in tracking and-1

, controlling the use of overtime..

o TVA will work with the unions to determine if changes in the union-contract should be made.

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4-4 l i U.S. Nuclear Regulatory Commission.

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'l TVA believes implenentation of tha 'above actions will provide:a-significant j

improvement in, overtime control. Monitoring will be continued to assess 3

effectivenessi TVA willLbe revising the-initial response,to'the NOV to reflect these additional corrective actionsfand provide'a revised'.date~for verifying full compliance.: This: revised response willf be submitted by-November 16, 1990. TVA's commitment to. revise'the' response to the'NOV:is f

containedrin the enclosure.

If you have any questionsEconcerning.this submittal, please telephone.

i M. A. Cooper at (615) 843-6422.:

l Very truly'yours,

' TENNESSEE VALLEY AUTHORITY l

t hh Mark O. Medford, Vice' President.

Nuclear Assurance,, Licensing:

,& Fuels-Enclosure cc (Enclosure):

Ms. S. C. Black, Deputy-Director j

Project Directorate II-4E c

U.S. Nuclear Regulatory Commission l

One White' Flint, North

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11555 Rockville Pike l

Rockville, Maryland =20852 Mr. J. N. Donohew,. Project Manager-I 4

U.S. Nuclear-Regulatory Commission-One White Flint, North l

11555 Rockville Pike Rockville, Maryland 20852 NRC Resident Inspector.

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.SequoyahxNuclear Plant I

2600aIgou Ferry Road 1

Soddy Daisy, Tennessee 37379 i

Mr. B. A. Wilson, Project Chief 4

U.S. Nuclear Regulatory Commission 1

Region.II 101 Marietta Street, NW,' Suite 2900 Atlanta, Georgia -30323 1

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-FRCLOSURE

.s, OVERTIME CONTROL..

I TVA'will revise its. response to Notice of Violation 50-327, 328/90-22-01, by November-16, 1990..

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