ML20070N887
| ML20070N887 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 01/03/1983 |
| From: | Papay L SOUTHERN CALIFORNIA EDISON CO. |
| To: | Engelken R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| Shared Package | |
| ML20070N878 | List: |
| References | |
| NUDOCS 8301250639 | |
| Download: ML20070N887 (3) | |
Text
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Southem Celifomia Edison Company h &.
R O. BOX 800 2244 WALNUT GROVE AVENUE ROSEM EAD, CALIFORNIA 91770 g
January'3, 1983 w......n
,r U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement e
Region V 6
73 1450 Maria Lane, Suite 210 Sg, Walnut Creek, California 94S96-5368 Wg s
fo A
Attention:
Mr. R. H. Engelken, Regional Administrator (3
9 4
Dear Sir:
A]po
Subject:
Docket No. 50-361 IE Inspection Reports 50-361/82-39, 50-362/82-31 Response to Notice of Violation San Onofre Nuclear Generating Station, Unit 2 Mr. J. L. Crews' letter of December 9,1982, issued IE Inspection Reports 50-361/82-39, 50-362/82-31 and forwarded a Notice of Violation resulting from the October 26 through November 8,1982 inspection conducted by Mr. A. Chaffee.
The enclosure to this letter provides the Southern California Edison Company response to the Notice of Violation contained in Appendix A of Mr.
Crews' letter of December.9, 1982.
I trust the enclosure responds adequately to all aspects of the violation.
If you '1 ave any questions or if we can provide additional information, please let me know.
l Sincerely, Wy 7
l Enclosure cc:
A. E. Chaffee (USNRC Resident Inspector - San Onofre, Units 2&3) 8301250639 830119 PDR ADOCK 05000361 Q
PDR 83-o1
.=
ENCLOSURE Response to the Notice of Violation contained in Appendix A to Mr. J. L. Crews' letter of December 9,1982.
Appendix A to Mr. Crews' letter of December 9,1982, states:
" Operating License NPF-10 section 2.C(19)b states, in part:
'1.
SCE shall develop and implement administrative procedures to limit the working hours of individuals of the nuclear power plant operating staff who are responsible for manipulating plant controls or for adjusting on-line systems and equipment affecting plant safety which would have an immediate impact on public health and safety.
Adequate shift coverage shall be maintained without routine heavy use of overtime.
However, in the event that unforeseen problems require substantial amount of overtime to be used, the following guidelines shall be followed:
a.
An individual shall 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 /> straight (excluding shift turnover time).
b.
An individual shall 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 seven day,,eriod (all excluding shift turnover time).
Any deviation from the above guidelines shall be authorized by the station manager, his deputy, the operations manager, or higher levels of management, in accordance with established procedures and with documentation of the basis for granting the deviation.
Controls shall be included in the procedures such that individual overtime will be reviewed monthly by the station manager or his designee to assure that excessive hours have not been assigned.
Routine deviation from the above guidelines is not authorized.'
Contrary to the above requirements:
1)
One Unit 2 Senior Reactor Operator worked 26 hours3.009259e-4 days <br />0.00722 hours <br />4.298942e-5 weeks <br />9.893e-6 months <br /> in a 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> period from September 6 through September 8, 1982 without appropriate management authorization.
2)
One Unit 2 Reactor Operator worked 25 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br /> in a 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> period from September 6 through September 8, 1982 without appropriate management authorization.
The same Unit 2 Reactor Operator worked a 17 hour1.967593e-4 days <br />0.00472 hours <br />2.810847e-5 weeks <br />6.4685e-6 months <br /> shift from September 7 through September 8, 1982, without appropriate management authorization.
"This is a severity level IV violation (Supplement I)."
v
.. RESPONSE 1.
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND RESULTS ACHIEVED Investigation into the incidents described in the above Notice of Violation revealed that, although scheduled overtime was being monitored and proper authorizations issued, unscheduled overtime, such as caused the specific deviations cited, was not always recorded and examined for compliance with the cited license provision. Unscheduled overtime can result from " holdovers" if, for example, a watch relief is late or shift change is otherwise delayed.
As Corrective Action, Operations promptly issued a memorandum' requiring approval of all overtime by the Watch Engineer. The resulting approval record is then incorporated into the overall tracking of overtime to assure compliance with the license.
2.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER ITEMS OF NON-COMPLIANCE The problem identified in the above Notice of Violation and the difficulty of keeping track of overtime worked from day-to-day has been discussed with the NRC, including the Resident Inspector and other personnel from Region V.
Station Order S0123-A-139, "NRC overtime Restrictions," and procedure S0123-VI-19.0, " Deviation from NRC Excessive Overtime Guidelines", were issued in October,1982 and training on the order and procedure were provided. Adherence to the provisions of the order and procedure will provide compliance with the license requirements for authorization of overtime. Based on the administrative difficulty of keeping track of all overtime, we are evaluating additional measures which may facilitate the administration of overtime tracking and approvals.
This may include the use of an Automatic Data Processing (ADP) system to simplify the record keeping.
Station management is acutely aware of the effects of overtime on operating personnel, and as the number of trained, licensed operators is increased, work schedules will be implemented to further reduce overtime requirements.
3.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance with the provision of Operating License NPF-10 was achieved on November 1,1982 with :he issuance by the Station Operations Manager of a memorandum governing the approval of unscheduled overtime.
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