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Insp Repts 50-269/84-16,50-270/84-15 & 50-287/84-26 on 840910-14.Violations Noted:Failure to Preclude Assignment of Administrative Duties to on-duty Personnel & Failure to Limit Overtime for Health Physicists
	ML20129H340
Person / Time
Site:	Oconee
Issue date:	11/13/1984
From:	Christensen H, Debs B, Julian C, Wagner P; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	;
Shared Package
ML20129H279	List: ML20129H277; ML20129H321; ML20129H340;
References
	RTR-NUREG-0737, RTR-NUREG-737, TASK-1.A.1.1, TASK-1.A.1.2, TASK-1.A.1.3, TASK-1.C.2, TASK-1.C.3, TASK-1.C.4, TASK-1.C.6, TASK-TM 50-269-84-16, 50-270-84-15, 50-287-84-26, NUDOCS 8507180620
	Download: ML20129H340 (11)
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Report Nos.: 50-269/84-16, 50-270/84-15, and 50-287/84-26

Licensee: . Duke Power Company

422 South Church Street

Charlotte, NC 28242

Docket Nos.: 50-269, 50-270, and 50-287 License Nos.: DPR-38, DPR-47, and

DPR-55

Facility Name: Oconee 1, 2, and 3

Inspection Conducted: September 1p-14, 1984

Inspectors:

B. Debs

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Date' Signed

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H. Christensen Da'te Signed

h. W & /t b3 S4-

P.Wagnerf Date Signed

Approved by: b n #/f/N ~

C. A. JuTian, Section Chief Uate Signed

Operational Programs Section

Division of Reactor Safety

SUMMARY

Scope: This routine, announced inspection involved 105 inspector-hours on site

in the areas of seven NUREG-0737 items including 1.A.1.1 Shift Technical Advisor;

1. A.1.2 Shi f t Supervisor Administrative Duties; 1. A. I.3 Shi f t Manning; 1.C.2

Shift Relief and Turnover; 1.C.3 Shift Supervisor Responsibilities; 1.C.4 Control

Room Access; and 1.C.6 Verification of Correct Performance of Operating

Activities. The inspection included a review of documents related to these

NUREG-0737 items as well as observation of control room activities and interviews

with Operations and Training personnel.

Results: Of the seven areas inspected, three violations were identified.

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REPORT DETAILS

1. Licensee Employees Contacted

M. Tuckman, Station Manager

J. Pope, Superintendent of Operations

L. Schmid, Duke Corporate Operations Support

R. Bond, Compliance Engineer

T. Coutu, Assistant Operations Engineer

0. Davidson, Compliance Associate Health Physicist

W. Gibson, Quality Assurance

H. Lowery, Shift Operations Engineer

T. Matthews, Compliance Technical Specialist

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Other licensee employees contacted included 14 operators,

NRC Resident Inspectors

J. Bryant, Senior Resident Inspector

K. Sasser, Resident Inspector

L. King, Resident Inspector

Attended exit interview

2. Exit. Interview

The inspection scope and findings were summarized on September 14, 1984,

with those persons indicated in paragraph 1 above.

3. Licensee Action on Previous Enforcement Matters

This subject was not addressed in the inspection.

4. Unresolved Items *

Unresolved items were not identified during this inspection.

5. 1.C.4 Control Room Access

This NUREG-0737 Action Item required licensees to revise plant procedures to

limit access to the control room to the individuals responsible for the

~ direct operation of the plant, technical advisors, specified NRC personnel,

and to establish a clear line of authority, responsibility, and succession

in the control room.

An' Unresolved Item is a matter about which more information is required to

determine whether it is acceptable or may involve a violation or deviation.

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i The inspectors observed two methods of controlling control room access in

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The first method restricts access to the entire control room complex by the

use of key cards and the procedures which govern their issue and use. The '

l second method of access control applies to a specific area within the

j control room complex. This area is known as the " Control Room Area" and is

! defined in the licensee's Station Directives 3.1.27, current revision dated

l January 18,1984, and 3.1.31, current revision dated August 8, 1984. In

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Station Directive 3.1.31 " Control Room Access and Authority", the Shift

j Supervisor or Control Room SR0 has the responsibility to ensure only

essential personnel are in the Control Room Area and that individuals must

obtain permission from them to enter the " Control Room Area".

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I The inspectors observed formal compliance with control room access

l procedures and found that the procedures adequately met the intent of -

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NUREG-0737.

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6. 1.C.3 Shift Supervisor Responsibilities

i This NUREG-0737 action item requires licensees to issue a corporate

management dirictive that clearly establishes the command duties of the

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shift supervisor and emphasizes the primary management responsibility for

safe operation of the plant. This item also requires the licensee to revise

plant procedures to clearly define the duties, responsibilities, and

! authority of the shift supervisor and the control room operators.

The licensee issues a management directive regarding Shift Supervisor

i Responsibility to "All Nuclear Production Personnel" annually, but the

distribution does not include vendor or contractor personnel. This annual

i directive requirement appears in Duke Power Company's McGuire and Catawba

i Nuclear Station Technical Specifications (McGuire Inspection Report

l No. 50-369/84-24 and 50-370/84-21); however, Oconee does not have this

, requirement in its Technical Specification.

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! The inspectors reviewed Administrative Policy Manual Sections 3.1.2.4 and

! 3.1.2.5, the licensee's Final Safety Analysis Report (FSAR) sections

! 13.1.2.2.5 and 13.1.2.2.6, Oconee Emergency Response Plan, and Station

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Directives 3.1.27 as revised January 18, 1984, 3.1.33 as revised January 23, ,

1984, and 3.1.36 as revised January 18, 1984. t

These procedures adequately define the shif t supervisors' responsibilities.

The inspectors however, expressed concern to licensee management that the

procedures do not adequately define the responsibilities and authority of

control room operators (unit supervisors and control room SR0/STA's) during

the onset of an "off normal" event.

In addition to these procedural reviews, the inspectors conducted interviews

with licensed operators regarding the responsibilities and authority of unit

supervisors and control room SR0/STA's during "off normal" events. These

interviews indicated that on the start of an off normal event when the shift

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supervisor may not be immediately available to take charge of the situation,

the command and control function becomes confused between the unit

supervisor and the control room SRO, both of which are assistant shift

supervisors. During some interivews, the SR0 in the control room and the

unit supervisor indicated they would be in charge of the event until

relieved by the shift supervisor. The SR0 in the control room also has the

responsibility to perform the function of STA.

In reviewing the licensee's procedures, the Administrative Policy Manual,

section 3.1.2.5, states, in part, that the assistant shift supervisor shall

assume the responsibilities of the shift supervisor in the absence of the

shift supervisor. Station Directive 3.1.27 states, in part, the control

room SRO/STA must be readily available to supervise control room activities

at all times. Station Directive 3.1.36 states, in part, that the control

room SR0/STA, during off-normal events, shall be detached from and

independent of the normal line function of shift operation and act as an

advisor to the shift supervisor. Additionally, he is to perform the normal

duties of an assistant shift supervisor from the control room during normal

operations.

The responsibilities and authority of an assistant shift supervisor are not

clearly defined in procedures, but the licensee indicated that a unit

supervisor is the same as an assistant shift supervisor. Station Directive

and administrative procedures are contradictory in defining the responsi-

bilities and authority of the unit supervisor and his function relative to

the control room SR0 at the start of an "off normal" event. The licensee

management was informed that this inadequacy is a matter that needs licensee

management attention for prompt clarification. (Inspector Followup Item

IFI) 50-269/84-16-01, 50-270/84-15-01 and 50-287/84-26-01).

7. 1.A.1.2 Shift Supervisor ^dministrative Duties

This NUREG-0737 item requires licensees to review the administrative duties

of the shift supervisor and delegate functions that detract from or are

subordinate to the management responsibility for assuring safe operation of

the plant to other personnel not on duty in the control room.

With regard to the aforementioned NUREG-0737 item, the inspectors conducted

a review of Oconee Station Directives and Administrative Policy Procedures.

Currently, no specific direction exists to specify all the administrative

duties that can be delegated by tae shift supervisor.

The inspectors conducted interviews with shift supervisors and assistant

shift supervisors. Interviewed shif t supervisors indicated that it was

their individual responsibility to delegate some administrative duties to

other personnel and that they did not consider themselves overburdened.

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The delegation of administrative duties may be made to the assistant shift

supervisors, who may be on duty in the control room. Procedures do not

exist to preclude the assignment of administrative duties to on duty

personnel who fulfill the 10 CFR 50 and Technical Specification control room

manning requirements.

The inspectors informed licensee management that the aformentioned practice

was not acceptable since nothing precludes assistant shift supervisors or

reactor operators (on duty personnel in the control room) from being

. burdened with detracting administrative duties. Therefore, the licensee has

not met the intent of this NUREG-0737 item which appears in USNRC Order

7590-01 dated July 10, 1981, Order Confirming Licensee Commitments On

Post-TMI Related Issues, issued to Duke Power Company.

10 CFR 2.204 states, in part, that the commission may modify a license by

issuing an order. The inspectors informed licensee management that the

inadequacy to preclude assignment of administrative duties to on duty per-

sonnel is a violation of Order 7590-01, which was issued under 10 CFR 2.204

(Violation 50-269/84-16-02, 50-270/84-15-02 and 50-287/84-26-02).

8. 1.C.2 Shift Relief and Turnover

This NUREG-0737 item requires licensees to revise plant procedures for shift

relief and turnover to require signed checklists and logs to assure that the

operating staff (including auxiliary operators and maintenance personnel)

possess adequate knowledge of critical plant parameters status, system

status, availability, and alignment.

The inspectors reviewed Station Directives 3.1.19, as . revised November 30,

1981, Unit Supervisors Log Book, and 3.1.20, as revised February 23, 1982,

Reactor Operation Log, and Operation Procedure OP/0/A/1102/20, Shift

Turnover, revision 24. Additionally, the inspectors conducted interviews

with selected operational personnel regarding shift turnovers. The

inspectors found the licensee to be in compliance with the NUREG-0737 action

item 1.C.2. The inspectors also noted that the licensee conducted reviews

and maintained the shift turnover sheets for a minimum of six months, in

accordance with Operation Procedure OP/0/A/1102/20.

The inspectors expressed concern over the lack of interim shift turnover

procedures to assure that the operating staff possess adequate knowledge

of critical plant parameters status, system status, availability, and

alignment. Interviews indicated that on the few occasions interim turnovers

have taken place, the turnover checklists were used for discussion, but no

signatures on these checklists were required.

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9. I.A.1.1 Shift Technical Advisor

This NUREG-0737 Action Item requires each licensee to provide an on-shift

technical advisor to the shift supervisor. The Shift Technical Advisor

(STA) may serve more than one unit at a multi-unit site if qualified to

perform the advisor function for the various units.

The STA shall have a bachelor's degree or equivalent in a scientific or

engineering discipline and have received specific training in the response

and analysis of the plant for transie,nts and accidents. The STA shall also

receive training in plant design and layout, including the capabilities of

instrumentation and controls in the control room. The licensee shall assign

normal duties to the STAS that pertain to the engineering aspects of

assuring safe operations of the plant, including the review and evaluation

of operating experience.

The inspectors reviewed Oconee Station Directive 3.1.36, as revised

January 18, 1984. This Station Directive states that the licensee's

SR0/STA: shall have a minimum of a high school diploma, or equivalent, and

four (4) years of responsible nuclear power plant experience. An SR0/STA

shall also hold a Senior Reactor Operator license. The licensee, in a

letter to the NRC dated May 21, 1984, committed to meeting the bachelor's

degree requirement by September 1, 1985.

The inspectors reviewed Oconee's Technical Specification section 6.1.1.7 and

Figure 6.1-1. Technical Specification 6.1.1.7, states, in part, that the

functions of the Shift Technical Advisor are fulfilled in the following

manner: An experienced SRO, who has been instructed in additional academic

subjects, will be assigned on-shift to provide the . accident assessment

capability. Technical Specification Figure 6.1-1, shows the STA as a

separate entity under the Operating Engineer with a dotted line to the Shift

Supervisor, indicating advisory responsibilities.

The inspectors conducted a review of correspondence between Duke Power

Company and the NRC and Station Directives 3.1.36, original dated July 1,

1980, and the current revision dated January 18, 1984. In a USNRC letter

dated April 7, 1980, the NRC conducted an evaluation of Oconee Nuclear

Station's actions taken to satisfy TMI-2 lessons learned. The evaluation

stated, in part, that the STA is an additional person assigned to each shift

who will provide on-shift accident assessment and will be independent of the

normal line function of plant operations. The evaluation also stated that

the licensee has satisfied the requirements of the STA and that verification

of the adequacy of the licensee's procedures for implementation of this item

will be performed by the office of Inspection and Enforcement and will be

documented in an appropriate inspection report.

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j Inspection Report Numbers 50-269/80-23, 50-270/80-20 and 50-287/80-17,

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states that the STA program es.tablished for all three Oconee units appears

to satisfy the requirements of the item. Station Directive 3.1.36 dated

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July 1, 1980, also states that the STA(s) will not take away from any of the

, established duties or responsibilities of the Shift Supervisors or the

i Assistant Supervisors. The STA will report directly to the Projects

Operating Engineer and not to the Shift Supervisor. STA responsibilities

during off-normal events shall be detached from and independent of the

normal line function of shift operation and act as an advisor to the Shift

Supervisor. During normal operation, the STA will perform duties as

directed by the Projects Operating Engineer.

Station Directive 3.1.36, as revised January 18, 1984, states that the

4 SR0/STA will provide additional on-shift capability for evaluation and

assessment of off-normal events and normal transients. The SR0/STA will be

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required in the control room from which the unit is operated any time the

reactor coolant temperature on that unit is above 200 F. SR0/STA will

! report directly to the Projects Operating Engineer and not to the Shift ,

i Supervisor on items pertinent to the STA function. He will report to the >

Shift Supervisor on items pertinent to normal operations. The SR0/STA

responsibilities, during off-normal events, shall be detached from and

independent of the normal line function of shift operation and act as an

l' advisor to the Shift Supervisor. During normal operations, he shall perform

duties of the control room supervisor as directed by the Shift Supervisor.

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He shall perform the normal duties of an assistant shift supervisor from the

control room during normal operations.

The inspectors expressed the concern that the current revision of Station

t Directive 3.1.36, establishes the STA as the SR0 in the control room. This

Station Directive now places the STA in the normal line function of plant

operation which may prevent him from promptly being detached from this line

function during an off-normal event. This Oconee Station Directive has

i combined the requirements for a SRO in the Control Room and a STA into

the same individual.

! The inspectors have informed the licensee management that the combined

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Control Room SR0/STA function does not meet the intent of NUREG-0737 and is

a violation of Technical Specification Figure 6.1-1, which shows the STA as

,_ a separate entity, not included in the normal line function under the Shift

i Supervisors (Violation 50-269/84-16-03, 50-270/84-15-03 and 50-287/84-26-03).

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10. 1.A.1.3 Shift Manning

This NUREG-0737 item requires, in part, that licensees of operating plants

and applicants for operating licenses shall include in their administrative

procedures (required by license conditions) provisions governing required

shift staffing and movement of key individuals about the plant. These

provisions are required to assure that qualified plant personnel are readily

available to man the operational shifts in the event of an abnormal or

emergency situation.

This action item also requires that these administrative procedures set

forth a policy requiring development of work schedules which avoid the

use of overtime, to the extent practicable, for the plant staff who perform

safety-related functions (e.g. , senior reactor operators, reactor operators,

health physicists, auxiliary operators, I&C technicians and key maintenance

personnel).

The aforementioned NUREG-0737 item was, in part, incorporated into Oconee

Technical Specification Table 6.1-1, Minimum Operating Shift Requirements.

In addition to reviewing this Technical Specification, the inspectors

reviewed a licensee proposed Technical Specification change to Table 6.1-1

dated July 16, 1984.

The NUREG-0737 requires five auxiliary operators on shift for three unit,

two control room operations. Oconee's Technical Specifications, Table

6.1-1, along with the proposed table change, indicate four auxiliary

operators. Additionally, NUREG-0737, requires five licensed reactor

operators if two units are being operated from two control rooms for a

three-unit plant. The current Technical Specification _is short one licensed

reactor operator. The proposed Technical Specification change correctly

reflects the required number of reactor operators.

The inspectors informed the licensee management of these discrepancies. The

licensee stated that action would be taken to correct Technical Specifi- .

cation Table 6.1-1. The licensee was informed that the discrepancies

associated with Technical Specification Table 6.1-1 will remain open as an

Inspector Followup Item until corrected (IFI 50-269/84-16-04, 50-270/84-15-04,

and 50-287/84-26-04).

The inspector conducted a review of the following documentation concerning

overtime limitations:

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Station Directive 3.1.33, revision dated January 25, 1984, Rules of

Practice.

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Duke Power Company letter to the NRC dated June 26, 1984, Proposed

revision to Technical Specifications 6.4.3.

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Proposed Draft Station Directive, " Limiting Work Hours".

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The licensee's Station Directive 3.1.33 states that operators are normally

scheduled to work twelve (12) hours per day. If overtime is required,

operators will not normally be scheduled for more than 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months per day or

120 hours0.00139 days 0.0333 hours 1.984127e-4 weeks 4.566e-5 months in a two-week period. Deviation from this policy must have the

approval of the Superintendent of Operations.

In general, utilization of personnel described above should be planned to

avoid necessity for working hours in excess of any of the following

(excluding extended periods of shutdown for refueling, major maintenance, or

major plant modifications):

a. An individual should not be permitted to work more than 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months

i straight, with 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months being the maximum time at the control board

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(excluding shift turnover time).

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b. There should be at least an.8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months break between all work periods

(including shift turnover time).

c. An individual should not work more than 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months in any seven day

period, more than 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months in any 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period, nor more than 24

hours in a,ny 48 hour5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months period (all excluding shift turnover time).

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d. The use of overtime should be considered on an individual basis and not

for the entire staff on a shift.

The' proposed Technical Specification 6.4.3 states, in part, administrative

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procedures shall be developed and implemented to limit the working hours of

station staff who perform safety-related functions, e.g., senior reactor

operators, reactor operators, nuclear equipment operators, and certain

maintenance personnel. Any deviations from the above procedures shall be

authorized by the Station Manager (or designee) in accordance with

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established procedures and with documentation of the basis for granting the

deviation. Individual overtime shall be periodically reviewed to assure

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that excessive hours have not been worked. Routine deviation from the above

guidelines is not authorized.

The inspectors expressed concern that health physicists or key maintenance

personnel are not currently included in Station Directive 3.1.33 and

i procedurally could work overtime which exceeded NUREG-0737 limits, but meet

licensee's limits of 120 hours0.00139 days 0.0333 hours 1.984127e-4 weeks 4.566e-5 months in a two-week period. Additionally, the

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proposed Technical Specification 6.4.3 change does not address overtime for

health physicists. Contrary to NUREG-0737 which was required by NRC order

7590-01, the licensee was informed that the Station Directive 3.1.33 and

proposed Technical Specification 6.4.3 were not adequate for limiting

overtime for health physicists and key maintenance personnel and were in

violation of NRC Order 7590-01 (Violation 50-269/84-16-05, 50-270/84-05-05,

and 50-287/84-26-05).

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11. 1.C.6 Verifying Correct Performance of Operating Activities

This NUREG-0737 action item requires that licensee's procedures be reviewed

and revised, as necessary, to assure that an effective system of verifying

the correct; performance of operating activities is provided as a means of

reducing human errors and improving the quality of normal operations. The

inspector conducted a review of Station Directive 4.2.5, revision dated

June 5,1984, and proposed Department Directive, " Independent Verification",

Revision 1, dated July 16, 1984. Station Directive 4.2.5 states that the

following methods are the acceptable ways of accomplishing Independent

Verification:

Two qualified individuals acting independently verify that affected

components are to be properly removed from service or returned to ,

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service by the direct observation of the component or the direct

performance of the necessary actions.

One qualified individual uses direct observation of the component or

directly performs the necessary actions followed by a second qualified

individual observing a remote indication.

Two qualified individuals using remote indication.

In the case of extremely strenuous tasks (such as operating large

valves), the verifier may help perform the function only under the

condition that verifier does not lose sight of his prime objective.

Independent Verification may be performed by individuals from the same

work area or another station section or group.

Personnel performing Independent Verification must be independently and

individually responsible for determining component status even though

they may be working together.

Responsibilities of the individual performing the removal and

restoration acts or service as the verifier must be clearly designated.

The inspectors expressed concern that the station directive allows two

qualified individuals to use a single remote indication when performing

independent verification and that two persons performing independent

verification may work together.

Licensee management was informed that the aforementioned methods of

accomplishing independent verification are contrary to IE Information Notice

No. 84-51, Independent Verification, dated June 26, 1984, in that

Independent Verification should be independent with respect to personnel,

i.e., two appropriately qualified individuals, operating independently,

should verify that equipment has been properly returned to service. Both

verifications are to be implemented by procedure and documented by the

initials or signature of the two individuals performing the alignment and

verification.

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In certain instances, it may be possible to accomplish one verification from

observing control room instruments, annunciators, valve position indicators,

etc. This is acceptable as long as the control room indication is a

positive one and is directly observed and documented.

Regarding the qualification of those who perform Independent Verification,

Station Directive 4.2.5 states that Independent Verification must be

performed by a qualified individual. Documentation or records pertaining to

an individual's qualification to perform Independent Verification is not

required.

Interviews with Station operations personnel indicated that the people

performing Independent Verification are work-area qualified, that is, the

nuclear equipment operator has completed the qualification task list for a

given work area.

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The inspectors expressed concern regarding Nuclear Equipment Operator

training, in that interviews with Nuclear Equipment Operators indicate

non-standardized means of completing Independent Verification of valve and

breakers. ' Licensee management indicated that they were implementing a

training program on Independent Verification which will cover methods of

accomplishing ' independent verification tasks. The inspector informed

licensee management that their current independent verification program does

not appear to meet the intent of NUREG-0737 Action Item 1.C.6, specifically

in light of subsequent NRC guidance provided in IE Information Notice

No. 84-51. This issue remains open as an Inspector Followup Item pending

further NRC review (IFI 50-269/84-16-06, 50-270/84-15-06, and

50-287/84-26-06).

ML20129H340

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