ML20101Q608
| ML20101Q608 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 07/08/1992 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 92-425, NUDOCS 9207150026 | |
| Download: ML20101Q608 (4) | |
Text
6 VinoixiA ELncTsuc Axu Pownn CoMarxy Itseitsono,Vinoisir uneni July 8, 1992 U. S. Nuclear Regulatosy Commission Serial No.92-425 Attention: Document Control Desk NAPS /JHL Washington, D. C. 20555 Docket Nos. 53 338 50-339 License Nos. NPF-4 NPF-7 Gentlemen:
VIRGINIA' ELECTRIC AND POWER COMPANY N_QBIfi ANNA POWER STATION UNITS 1 AND 2 INSEECTION REPORT NOS. 50-338/92-13 AND C0-339/92-13 RESPONSE TO THE NOTICE OF VIOLATION We have reviewed your letter of June 12, 1992, which referred c., the inspection conducted at North Anna Power Station from April 19,1992, through May 16,1992, and reported in Inspection Report Nos. 50-338/92-13 and 50-339/92-13. The letter also transmitted a Notice of Violation that was identified during the 'nspection. Our responsa to the Notice of Violation is attached.
In your letter that transmitted the Notice of Violation, you expressed concern over the deviations from the nuclear plant staff working hour limits that ws.e inappropriatelty authorized on a routine basis for outages and emergency plan coverage. The basis for your concern was that routinely exceeding overtime limits could lead to significant reductions in the offectiveness of personnel due to fatigue. We are in agreement that this issue rec;uires additional attention.
To resolve the issue, Virginia Power Administrative Procedure VPAP-0103, Working Hours and Limitations, was revised to clarify the Station Manager's responsibilities for-authorizing overtime and to provide guidance on what is intended by the term
" unusual circumstance" that would permit management to authorize personnel overtime above the established limits. A memorandum from the Station Manager was distributed to all station personnel that emphasized the overtime limitations of VPAP-0103 and management's expectaticas for procedure compliance.
In addition,
-appropriate measures have been taken to ensure that maintenance personnel I
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e providing Emergency Plan implementing Procedura coverage do not exceed the overtime requirements specified in VPAP-0103.
If you have any further questions, please contact us.
Very truly yours, l
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W. L. Stewart Senior Vice President - Nuclear Attachment
- cc: U. S. Nuclear Regulatory Commission 101 Marietta Street, N.W.
~ Suite 2900 Atlanta, Georgia 30323 Mr. M. S. Lesser NRC Senior Resident inspector North Anna Power Station i
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RESPOh8SE TO THE NOTICE OF VIOLATIOP 1NSPECTION REPORT NOS. 50-338/92-13 AND 50-339/92-13 i
NRC COMMENT During an NRC inspection conducted on April 19 - May 16,1992, 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, (1991), the violation le listeo below:
Techrical Specification Table 6.2-1 requires that procedures will be establir>hed to insure that NRC policy statement guidelines regarding wore.ing hours established for emp!oyees are followed.
Generic Letter 82-12, Nuclear Power Plant Staff Working Hours, establisi.es NRC l
policy statement guidelines on overtime limits, one of w'1ich is 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in any l
seven day period and that deviation from the guidelinee,,iay be authorized under very unusual circumstances.
Contrary to the above, VPAP-0103, Working Hours and Limitations, failed to adequately ir.sure that the NRC policy statement guidelines were followed in that personnel routinely, and on a w;despread basis, exceeded 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in seven day i
periods for conducting outage activities and maintaining emergency plan standby coverage.
This is a Severity Level IV Violation (Supplement 1).
RESPONSE TO THE NOTICE OF VIOLAT1QE l
1.
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION The violation is correct as stated.
2.
REASON' FOR THE VIOLATION The violation was caused by an improper management interpretation of l
requirements for allowed overtime. In addition, Virginia Power Administrative Procedure VPAP-0103, Working Hours and Limitations, did not adequately define L
an unusual circumstance that would allow approval for exceeding overtime limits.
Therefore, management interpreted an unusual circumstance as including a refuehg outage and Emergency Plan implementing Procedure (EPIP) coverage.
Based on this interpretation, management authorized personnel to exceed the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in a '7 day period overtime limit allowed by NRC Generic Letter 82-12.
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3.
CORRECTIVE STEPS WHICH HAVE -BEEN TAKEN AND THE --
RESULTS ACHIEVED
~ Virginia Power. Administrative Procedure VPAP 0103, Working Hours and Limitations, was revised to clarify the Station Manager's responsibilities for p
authorizing overtime and provide guidance on what is intended by the term
" unusual circumstance" that would perrnit management to authorize personnel overtime above the established overtime umits.
A memorandum from the Station Manager to all station personnel, dated June 16, 1992, discussed the limitations on the hours of work at-the plant, clarified the description of an unusual circumstance, emphasized the need to obtain approval prior to exceeding overtime limitetions and. discussed the supervisory
- responsibilities for monitoring the overtime hours worked by staff employees.
Appropriate measures-have been taken to ensure that maintenance personnel providing Emergency Plan implementin0 Procedure coverage do not exceed the overtime requirements specified in VPAP-0103,
- 4. -CORRECTIVE STEPS WillCH WILL BE TAKEN TO AVOll? FURTHER VIOLATIONS No further corree ive actions are required.
i 5.
THE DATE WHEN FULL-COMPLloNCE WILL BE ACHIEVED Full compliance has been achievod.
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