ML20059E516
| ML20059E516 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 08/19/1993 |
| From: | Rueger G PACIFIC GAS & ELECTRIC CO. |
| To: | |
| References | |
| OLA-2-I-MFP-072, OLA-2-I-MFP-72, NUDOCS 9401110248 | |
| Download: ML20059E516 (7) | |
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$A h.,u.y M Pacific Gas and Electric Company 77 Bea!e Street. Room 1451 g'
RD Box 770000 Ser:Or V4ce President ared Sr Fmasca CAM 177 GrerilManiged0 -
415 573 4534 iLiw Pc?.erGirsa: ion Fa4 415,$73-2313 March 26, 1993
- 93 OCT 28 'P6 :09 PG&E Letter No. DCL-93-070
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U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C.
20555 Re:
Docket No. 50-275, OL-DPR-80 l
Docket No. 50-323, OL-DPR-82 Diablo Canyon Units 1 and 2 Licensee Event Report 1-92-021-01.
Technical Specification 6.2.2 Overtime Restriction Violations Due, to Inadequate Overtime Control Program Gentlemen:
Pursuant to 10 CFR 50.73(a)(2)(1)(B), PG&E is submitting.the encloseo revision to Licensee Event Report 1-92-021 concerning Technical Specification 6.2.2. overtime restrictions being exceeded.
This revision is being submitted to report the root cause and applicable corrective actions for this event.
I Sincerely, I
8 W Y" 3
Gregory M. Rueger cc:
Ann P. Hodgdon John B.' Martin Mary H. Miller Sheri R. Peterson
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LICENSEE EVENT REPORT (LER) 7 ACIUTU N AME (tl DOCEET NtAAGER (7)
PAQ [ (3) i DIABLO CANYON UNIT 1 0l5l0l0l0l2l7l5 1
'l 6
TECHNICAL SPECIFICATION 6.2.2 OVERTIME RESTRICTION VIOLATIONS DUE TO INADEQUATE OVERTIME man CONTROL PROGRAM EVENf DQ1E fel 1ER NUMBER iel REPORT DATE in OTH(D SACILITIES INVOLVED (8)
MON DAY YR VR S$ O HAL REVISeON MON DAY YR DOCKET NLAASm (4)
DIABLO CANYON UNIT 2 11 17 92 92 0l2l1 0l1 03 26 93 0
5 0l0 0
4 G TH1$ REPORT l$ SUBMlifED PUR$UANT TO THE R(QUIRf.M(NTS OF 10 CFRt (11) 6 LNEL x
10 CFR 50.73(a)(2)ti)(B) 0l 0l 0 OTHER (Specify in Abstract below and in text, NRC Form 366A) l UCENstf CONTACT FOR T648 (FR f tM if L E PH%f NUMB [R DAVID P. SISK, SENIOR REGULATORY COMPLIANCE ENGINEER
^"(* c"5 805 545-4420 COMPLETE ONE UNE FOR EACH COMPONI.NT F AILURE DESCRBSED IN 1648 REPORT (th CAUS[
5YSTEM COMPONENT MANUFAC.
R(PO A E CAUSC 3YSTEM COMPONENT MANUFAC.
R PORT E
I III III I
III III I
III III I
III II SuPPuMENTAL REPORT EXPtCTED Het EXPECTED M Ntn DAY vtAR SUBMISSION l l YES (if yes, COmtete EXPECTED SUBMIS$10N DATE) lX l NO DATE W AQS1RACT (18)
On November 17, 1992, PG&E determined that failures to meet Technical Specification (TS) 6.2.2 regarding overtime restrictions, which occurred during the Unit 1 fifth refueling outage, were reportable in accordance with 10 CFR 50.73(a)(2)(1)(B).
j The root c..nes of this event u e datermined to be lack of adequate management involvement in the implementation of the overtime control program, and insufficient guidance from the overtime procedure.
Applicable personnel have been sensitized regarding the requirements of TS 6.2.2 by the use of tailboards and memoranda.
Inter-Departmental Administrative Procedure (IDAP) OM14.IDI, " Overtime Restrictions," was revised to improve the-clarity of the overtime restriction requirements.
In addition, a plant memorandum was issued to plant management requesting that plant management review the requirements of IDAP OM14.IDl.
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i LICENSEE EVENT REPORT (LER) TEXT CONTINUATION au ("
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I.
Plant Conditions Unit I was in Mode 6 (Refueling).
II.
Description of Event A.
Summary:
On November 17, 1992, PG&'E determined that failures to meet Technical Specification (TS) 6.2.2-regarding overtime restrictions, which occurred during the Unit 1 fifth refueling outage (IRS), were reportable in accordance with 10 CFR 50.73(a)(2)(1)(B).
B.
Background:
TS 6.2.2 requires that, during refueling, the following guidelines shall be followed:
an individual should not be permitted to work more than 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> in any 24-hour period, nor more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in any 48-hour period, nor more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in any 7-day period, all excluding shift turnover time. Any deviation from the above guidelines shall be authorized by the Plant Manager or his designee in accordance with established procedures. The procedures also require that the basis for granting the deviation be documented and that individual overtime shall be reviewed monthly by the Plant Manager or his designee to assure that excessive hours have not been assigned.
Koutine deviation from the above guidelines is not authorized.
l C.
Event Descriptions During 1RS, a Quality Assurance (QA) refueling activity audit identified several instances where plant personnel exceeded TS 6.2.2 overtime restrictions without proper authorization.
A subsequent investigation was conducted to determine the extent of the problem.
The following occurrences were identified:
l 1.
Three noncompliances with TS 6.2.2 occurred between September 14 and November 12, 1992, by Operations personnel. Two involved exceeding 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in a 7-day period and one involved exceeding 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in a 48-hour period.
2.
Five noncompliances with TS 6.2.2 occurred between October l
23 and October 31, 1992, by Maintenance personnel. All five involved personnel working in excess of 72-hours in a 7-day period.
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LICENSEE EVENT REPORT (LER) TEXT CONTINUATION
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PAGE (3) ma manaw mvmon DIABLO CANYON UNIT 1 0l5l0l0l0l2l7l5 92
- 0l2l1 0l1 3 l'l6 TEXT (17) 3.
Three noncompliances with TS 6.2.2 occurred during 1R5 by Quality Control (QC) personnel. Two involved exceeding 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in a 7-day period and one involved exceeding 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in a 48-hour period.
4.
Radiation Protection (RP) identified that some.of their personnel exceeded TS 6.2.2 limits.
These occurrences may
)
be characterized as personnel exceeding 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 personnel exceeding 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in a 7-day.
period.
5.
A sample review identified noncompliance with TS 6.2.2 limits by Nuclear Engineering and Construction Services (NECS) without prior authorization.
The nonconformances were overtime in excess of 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, 24 b,urs in a 48-hour period, and 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in a 7-day period.
On November 17, 1992, a Technical. Review Group (TRG). determined that a j
failure in administrative control of employee overtime occurred during i
1R5 and this failure was reportable in'accordance with 10 CFR I
50.73(a)(2)(1)(B).
D.
Inoperable Structures, Components, or. Systems that Contributed to the Event:
None.
E.
Dates and Approximate Times for Major Occurreries:
_~-
1.
October 26, 1992:
A QA audit identified several noncompliances with TS 6.2.2.
2.
November 17, 1992:
Event Date/ Discovery Date - A TRG determined that a failure in administrative control of employee overtime existed.
F.
Other Systems or Secondary Functions Affected:
None.
G.
Method of Discovery:
During 1R5, a QA refueling activity audit identified several instances where personnel exceeded TS 6.2.2 overtime restrictions without proper 1104S/85K l
LICENSEE EVENT REPORT (LER) TEXT CONTINUATION LER MVMSER 1 6)
PAGE (3)
DOCKET NUM9ER (2)
- hc3LITV NAME (3)
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=
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0l2l1 0l1 4 l'l6 DIABLO CANYON UNIT 1 0l5l0l0l0l2l7l5 92 TEST (37) authorization.
On November 17, 1992, a TRG determined that some of the occurrences described above constituted a failure in administrative controls of employee overtime.
H.
Operator Actions:
None required.
I.
Safety System Responses:
None.
III. Cause of the Event A.
Immediate Cause:
The preliminary cause of these events is management failure to correctly interpret procedural requirements to obtain written authorization prior to working overtime hours.
B.
Root Cause:
1.
Lack of adequate management involvement in the implementation of the overtime control program.
2.
The overtime procedure did not provide sufficient guidance in areas such as turnover time Aafinition, use of blanket authorizations, and organizational applicability of the requirements.
IV.
Analysis of the Event QC engineers, supervisors, plant operators, maintenance workers, NECS personnel, and RP workers did not comply with the overtime restriction of TS 6.2.2.
Personnel time records were reviewed in detail by plant management to determine what safety-related work may have been performed during that time period. The types of safety-related work performed by these individuals consisted of maintenance and work performed on 10 CFR 50 Appendix R modifications, residual heat removal piping (BP)(PSP) modifications, and modifications on the main feedwater piping (SJ)(PSP) near the steam generators (AB)(HX). These types of activities involved step-by-step procedural adherence, independent verification, quality verification, and overall supervision by on-shift operations personnel.
The performance of independent verifications following these activities served to mitigate the possibility that these TS 6.2.2 noncompliances would have had a 1104S/85K
LICENSEE EVENT REPORT (LER) TEXT CONTINUATION fcCILITV NAME (t)
Docart NUM91R (2)
LfR NUMBER i6)
POGE (3)e "M"
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DIABLO CANYON UNIT 1 0l5l0l0l0l2l7l5 92
- 0l2l1 0l1 5 l 'l 6 T127 (17) significant impact on plant safety.
Thus, the noncompliances with TS 6.2.2 limits did not adversely affect the health and safety of the public.
V.
Corrective Actions A.
Immediate Corrective Actions:
1.
The plant personnel who were found to have violated TS 6.2.2 were tailboarded regarding the requirements of TS 6.2.2.
2.
On October 28, 1992, a memorandum was issued to NECS personnel to ensure that personnel were aware of the overtime requirements in Inter-Departmental Administrative Procedure (IDAP) OM14.IDI,
" Overtime Restrictions."
3.
On October 28, 1992, a memorandum,_"Conformance with OM14.IDI,
' Overtime Restrictions,'" was issued to managerial personnel.
The memorandum requested that all managerial personnel review the requirements of IDAP OM14.IDI.
B.
Corrective Actions to Prevent Recurrence:
1.
The Operations administrative guideline regarding turnover and l
quitting time was revised to require that Operations personnel seeking to exceed the established work limits of IDAP OM14.IDI l
will not do so 'mtil the appropriate approval has been obtained.
2.
After consulting the applicable departments and members of management, and incorporating the revisions made to the Operations administrative guideline, IDAP OM14.IDI was revised to include the following:
t a.
Identification of organizational applicability.
1 b.
Identification of shift turnover time.
c.
A checklist, attached to the authorization form, to aid I
the overtime authorizer in determining that all requirements of the TS overtime limits have been met prior to granting approval, d.
A definition of blanket authorizations and a. statement that they shall not be authorized.
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f LICENSEE EVENT REPORT (LER) TEXT CONTINUATION vaa u rr a wr m mcm anta m ua ara o
not m DIABLO CANYON UNIT 1 0l5l0l0l0l2l7l5 92 0l2l1 0l1 6 l*"l6 ren tu>
VI.
Additional Information A.
Failed Components:
None.
B.
" evious LERs on Similar Problems:
LER 1-89-017-00, " Personnel Performing Safety-related Activities Exceeded TS Overtime Restrictions Without Proper Authorization" An investigation concluded that plant personnel had exceeded the TS 6.2.2 overtime restrictions without proper authorization on numerous-occasions. The. root cause of this event was' personnel error due to a lack of specific guidance in administrative procedures on the applicability and implementation of the TS overtime restrictions of-plant personnel. Corrective actions included revising the applicable administrative procedure to clearly inform all plant personnel of the scope of the procedural requirements.
Lack of adequate management involvement in the implementation of the overtime control program is the reason why previous corrective actions do-not appear to have been effective for preventing recurrence of unauthorized overtime as described in this LER.
m.
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