ML20207G548

Responds to NRC Re Severity Level IV Violation Noted in Insp Repts 50-413/88-22 & 50-414/88-22 Concerning Misinterpretation of Tech Specs

ML20207G548
Person / Time
Site:	Catawba
Issue date:	08/08/1988
From:	Tucker H DUKE POWER CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
NUDOCS 8808240156
Download: ML20207G548 (3)

Text

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e-e DuxE POWER COMPm P.O. BOX 33189 CHARLOTTE. N.C. 98949 menow HALB.Tt*CKER

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mmu-m August 8, 1988 U. S. Nuclear Regulatory Commission Washington, D. C.

20555 Attention: Document Control Desk

Subject:

Catawba Nuclear Station, Units 1 and 2 Docket Nos. 50-413 and 50-414 NRC Inspection Reports Nos. 50-413, -414/88-22 Reply to a Notice of Violation Gentlemen:

Please find attached Duke Power Company's response to Severity level IV violation No. 50-413, -414/88-22-01 which was transmitted by V. L. Brownlee's (NRC) letter dated July 08, 1988. This violation was attributed to a misinterpretation of Technical Specifications with regard to the engineering staff.

Nery truly yours, M

Hal B. Tucker l

JGT04.lec Attachment l

Dr. J. Nelson Grace Regional Administrator l

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U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 Mr. P. K. Van Doorn NRC Resident Inspector Catawba Nuclear Station I

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DUKE POWER COMPANY CATAWBA NUCLEAR STATION VIOLATION 413, 414/88-22-01 AUGUST 8, 1988 Technical Specification 6.2.2f requires in part that:

Administrative procedures shall be developed and implemented to limit the working hours of unit staff who perform safety-related functions (e.g., licensed Senior Operators, licensed Operators, health physicists, auxiliary operators, and key maintenance personnel).

Adequate shift coverage shall be maintained without routine heavy use of overtime. The objective shall be to have operating personnel work a nominal 40-hour week while the unit is operating. However, in the event that unforeseen problems require substantial amounts of overtime to be used, or during extended periods of shutdown for refueling, major maintenance, or major plant modification, on a temporary basis the following guidelines shall be followed:

1.

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.

2.

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 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.

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 shift turnover time.

4.

Except during extended shutdown periods, the use of overtime should be considered on an individual basis and not for the entire staff on a shift.

Any deviation from the above guidelines shall be authorized by the station Manager or his designee, or higher levels of management, in accordance with established procedures and with documentation of the basis for granting the deviation.

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Contrary to the above, during January and February 1988, personnel exceeded l

overtime guidelines on nunerous occasions without prior approval.

Admission or Denial of the Violation Duke Power admits the violation.

Reason for the Violation if Admitted i

l Management misinterpretation of Technical Specification with regerd to the I

engineering staff.

l Corrective Steps Which Have Been Taken and the Results Achieved An upcoming revision to an existing Technical Specification Interpretation 1.

and a Station Directive will place all exempt and non-exempt personnel who are performing safety related function under Technical Specification t

6.2.2.f.

s 2.

Section head was counselled. He advised his supervisors of the official Technical ~ Specification Interpretation.

l Corrective Steps Which Will Be Taken to Av id Further Violation With the corrective steps in section 3 above in place, all further violations should be avoided.

Date When Full Compliance Will Be Achieved Duke Pcwer will be in full compliance on September 30, 1988.

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