ML20101B859

Responds to NRC Re Violation Noted in Insp Rept 50-443/92-05.Corrective Action:Shift Schedule Form Will Be Revised to Delineate Exact Working Hours for Weekend or 12 H Shift

ML20101B859
Person / Time
Site:	Seabrook
Issue date:	06/04/1992
From:	Deloach R PUBLIC SERVICE CO. OF NEW HAMPSHIRE
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NYN-92075, NUDOCS 9206050213
Download: ML20101B859 (5)

Text

1 l '

New Hamnshire

' Yankee NYN 92075 J u'ie 4,1992 United States Nuclear Regulatory Commission Washington, D.C. 20555 Attention: Document Control Desk

References:

(a) Facility Operating License No. NPF-86, Docket No. 50-443 (b) USNRC Letter dated hiay 5, 1992, N R C Region 1 inspection 50-443/92 05 (3 3-92/4-6-92)," J, C. Linvine to T. C. Feigenbaum

Subject:

Reply to a Notice of Violation 5- j Gentlemem in accordance with the requirements of the Notice of Violation contained in Reference (b), the New Hampshire Yankee response to th: cited violation is provided as Enclosure 1.

Should you have any questic,ns concerning this response, please contact hir. James hl.

Peschel, Regulatory Compliance hianager, at (603) 474-9521, extension 3772.

Very truly yours, jfb b- ic{

R. Jeb DeLoach Executive Director .

l Engineering and Licensing RJD:TGP/act ,

Enclosure STATE OF NEW ll AN1PSHIR E Rockingham, ss. June 4,1992 Then personally appeared before me, the above-named R. Jeb DeLoach, being duly i

sworn, did state that he is Executive Director of Engineering and Licensing of the New g Hampshire Yankee Division of Public Service Company of New Hampshire, that he is duly c

.. y authorized to execute and file the foregoing information in the name and on the behalf of co n. New Hampshire Yankee Division of the Public Service Company and that the statements

$8 therein are true to the best of his knowledge and belief.

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$8 Tracy 'A. DeCredico, Notary Public a m -,ener"sdO /yi o o.

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o~ a.0 New Hampshire Yankee Division of Public Service Company of New Hampshire P.O. Box 300

• Seabrook, NH 03874

• Telephone (603) 474 9521

. United States Nuclear Regulatory Commission June 4,1992 Attention: Document Control Desk Page two cc: Mr. Thomas T Martin Regional Administrator U. S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406 Mr. Gordon E. Edison, Sr. Project Manager Project Directorate I 3 Division of Reactor Projects U.S. Nuclear Reg 9atory Commission Washington, DC 20555 Mr. Noel Dudley NRC Senior Resident Inspector P.O. Box 1149 Seabrook, NH 03874 m.,a -

l New llampshire Yankee June 4,1992 ENCLOSURE 1 TO NYN 42075.

a N

REPl Y TO A NOTICE OF VIOL,ATION Violation During an NRC Inspection conducted March 3 - April 6, 1992, a violation of NRC requirements was identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, the violation is listed below:

Technical Specification 6 2.2.(c) requires administrative procedures be developed and implemented to limit the working hours of station staff who perform safety-related functions, such as licensed operators. New llampshire Yankee Station Management Manual, Chapter 2, Section 6.2, " Extended Work llour Requirements For Safety-Related Functions,' requires Station Manager's authorintion documented on SSMM For m 4 4 A, " Extended Work llo u r.s Authorization," for any iedividual to work more than ~24 hours within 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> period.

Contrary to the above, since September 1991, both licensed and non licensed operators did not receive Station Manager's documentation authorization prior to working more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> within a 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> period as a result of modified shift iotations on weekends. '.

This is a Severity Level IV violation (Supc;ement 1).

REPLY Reason for the Violatio_n..

New ilampshire Yankee (NHY) has determined that the reason fer this violation was an inadequate implementation of the Seabrook Station Management Manual (SSMM), Chapter 2, Section 6.2 policy for "Workir g H o u r s." During the inception of the Operations ~

Department shift schedule in May 198S, the Operations Department developed twelve (12) hour shifts for Saturdays and Sundays. This schedule climinates an eight /8) hour shift D during the weekends, allowing the personnel to work two (2) weekends out of six (6), instead of three (3) weekends out of six (6).

The normal shift schedule for the Operations Department specifies three (3), eight hour shifts during the week and two (2), twelve he: r shifta on the weekends. The weekday shifts consist o! the day shift which is scheduled irc m 7:) Dam to 3:00pm, the swing shift which is scheduled from 3:00pm to 11:00pm, ar.d the mianight shift which is r,cheduled from 11:00pm to 7:00am. On the weekends, the " day shi't would get the week nd off and the swing and midnight shifts' hours would be extended. The schedule would specify the swing shift crew to -vork from 11:00am to 1100pm and the midnight shift crew to work from 11:00pm to 11:00am.

Contrary to the above, several operations crews changed the work hours in order to accommodate the specia' challenges of working the midnight shift. Working the midnight shift places additional demands on the shift crew to maintain their alertness when that chift is extended well into the day. Therefcre the midnight shift preferred working 7:00pm to

~

7:00am on the weekends. This necessitated the swing shift to v ark from 7:00am to 7:00pm

'on the weekends.

In opting for the 7:00am to 7:00pm hours for the swing shift, the operations crews 'ooked at the shift schedule as requiring 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for the shift and failed to relate that period to the previous Friday's 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> shift. The swing shift crew that started their 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> shift at 7:00am Saturday morning had just completed their 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> shift Friday evening at 11:00pm.

The cornbination of the 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> shift Friday and the 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> shift Saturday and Sunday caused the crew to work greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (i.e. 28 hours3.240741e-4 days <br />0.00778 hours <br />4.62963e-5 weeks <br />1.0654e-5 months <br />) within a 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> ti ic period (i.e., Friday 3:00pm to Sunday 3:00pm). Had the crew properly applied the " Extended Work Hours Authorization Policy" er, defined in SShiht Chapter 2, Section 6.2, a request for Station Manager Authorization would hm We'i utilized.

Corrective Action to P event i Recurrence To preclude a recurrence of an event of this type, the Operations Manager issued a night order in the Operations Night Order Book which in part, directed the crews to adhere to the established II:00am to 11:00pm weekend schedule. Deviation from the 11:00am to 11:00pm schedule must be approved ' . the Shift Superintendent aed either the Operations Manager or the Assistant Operations Manager. Should an approved shift deviation create an extended work hour condition, documented Station Manger authorization must be obtained prior to the shift. In addition to the immediate action, the follov'ing long term actions will be irnplemented:

1) The shift schcdule form will be revised to delineate the exact working hours for a weekend or 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> shift.

2) An enhanced tracking program will be developed using a sliding scale (hourly) to assist in the determination of any work hour limitations conflicts.

3) A procedure will be developed to control personnel hour swapping. This procedure will provide strict controls and an appiopriate level of review and approval. _

Date of Full Comoliance New Hampshire Yankee is currently in full compliance with Technical Specification 6.2.2.(e).

It is anticipated that the long term corrective actions described above will be completed by June 30,1992.