ML20155F077
| ML20155F077 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 09/30/1988 |
| From: | Tucker H DUKE POWER CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8810130122 | |
| Download: ML20155F077 (3) | |
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$lC4)??] 4HI DUKE POWCR September 30, 1988 U. S. Nuclear Regulatory Comission i
Washington, D. C.
20555 I
Attention: Document Control Desk 1
Subject:
Catawba Nuclear Station, Units 1 and 2 Docket Nos, 50-413 and 50-414 NRC Inspection Reports Nos. 50-413. -414/9d-2.
Reply to a Notice of Violation Gentlemen:
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l Please find attached Duke Power Company's revised respor'se to Soverity level IV l
violation No. 50-413. -414/88-22-01 which was transmitted by V. L. Brownlee's j
(NRC) le.tter dated July 8, 1988.
This violation was attributea to a misinterpretation of Technical Specifications with regard to the etigineering staff.
I Very truly yours, i
Ms < n
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d Hal B. Tucker Itl./
Attachment xc Dr. J. Nelson Grace, Regional Administrator U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, hN, Suite 2900 Atlanta, Georgia 30323 5
Mr. W. T. Orders i
NRC Resident Inspector f
i Catawba Nuclear Station l0' i
8810130122 000930 l
gDR ADOCK 05000413 PNU i
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1 DUKE PWER COMPANY l
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CATAWRA NUCl.FAR STATION i
VIO!.ATION 413, 414/88 22-01 l
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l Technical Specification 6.2.2f requires in part that:
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Administrative procedures shall be developed and implemented to limit the working i
hours of unit staff who perform safety related functions (e.g.
licensed Senior Operators. licensed Operators, health physicists auxiliary operators, and key l
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maintenanace personnt'.).
l Adequate shift coverage shall be maintained wothout routine heavy use of
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j overtime. The objective shall be to have operating personnel work a nominal
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40-hour week while the unit is operating.
However, in the event that unforeseen i
problems require substantial amounts of overtime to be used, or during extended i
periods of shutdown for refueling, major maintenance, or major plant modification, on a temporary basis the following guidelines shall be followed i
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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 /> straight excluding shift turnover time.
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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 I
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.
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3.
A break of at least 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> should be allowed between work periods, including i
J shift turnover time.
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Except during extended shutdown periods, the use of overtime should be l
l considered on an individual basis and not for the entire staff on a shift.
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Any deviation from the above guidelines shall be authorized by the Station J
i Manager or his designeo, or higher levtis of management, in accordance with established procedures and with documentation of the basis for granting the l
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I Contrary tn the above, during January and February 1988, personnel exceeded i
overtime guidelines on numerous occasions without prior approval.
Admission or Denial of the Violat ion l
Duke power admits the violation.
l Reason for tho Violatlon if Admitted 4
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Management misinterpretation of Technical Specification with regard to the I
j engineering staff.
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Corrective Stepn Which llave Been Taken rnd ths Results Achievej b
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An upcoming revision to an existing Technical Soccification Interpretation l
1 and a Station Directive will better define the method and intent of j
controlling overtime as described in Technical Specification 6.2.2.f.
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2.
Section ihad was counselled. lie advised his supervisors of the official
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Technical Specification Interpretation.
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i Corrective Steen Which Vill Bn Taken to Avoid Further Violations
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With the corrective steps in 3ection 3 above in place, all further violations
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will be avoided.
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l Dato When Full Complianen Will Be Achieved I
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j Duke power will comp!ete the revisions to th9 Station Directive and Technical i
Specification Interpretation before November 15, 1988.
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