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| | number = ML20129G294 | | | number = ML20129G294 |
| | issue date = 12/21/1984 | | | issue date = 12/21/1984 |
| | title = Responds to NRC 841123 Ltr Re Noncompliance Noted in Insp Repts 50-269/84-16,50-270/84-15 & 50-287/84-26.All Three Violations Denied.Concomitant Justification Provided | | | title = Responds to NRC Re Noncompliance Noted in Insp Repts 50-269/84-16,50-270/84-15 & 50-287/84-26.All Three Violations Denied.Concomitant Justification Provided |
| | author name = Tucker H | | | author name = Tucker H |
| | author affiliation = DUKE POWER CO. | | | author affiliation = DUKE POWER CO. |
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| | case reference number = RTR-NUREG-0737, RTR-NUREG-737, TASK-1.A.1.2, TASK-1.A.1.3, TASK-TM | | | case reference number = RTR-NUREG-0737, RTR-NUREG-737, TASK-1.A.1.2, TASK-1.A.1.3, TASK-TM |
| | document report number = GL-82-33, NUDOCS 8507180011 | | | document report number = GL-82-33, NUDOCS 8507180011 |
| | | title reference date = 11-23-1984 |
| | package number = ML20129G285 | | | package number = ML20129G285 |
| | document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC | | | document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC |
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| ==Dear Sir:== | | ==Dear Sir:== |
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| In response to your letter dated November 23, 1984 which transmitted the subject Inspection Report, the attached response to the cited item of non-compliance is provided. I declare under penalty of perjury that the statements set forth herein are true and correct to the best of my knowledge on December 21, 1984. | | In response to your {{letter dated|date=November 23, 1984|text=letter dated November 23, 1984}} which transmitted the subject Inspection Report, the attached response to the cited item of non-compliance is provided. I declare under penalty of perjury that the statements set forth herein are true and correct to the best of my knowledge on December 21, 1984. |
| Very truly yours, C | | Very truly yours, C |
| / | | / |
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| With this change, and the existing Technical Specifications I | | With this change, and the existing Technical Specifications I |
| and station directives, it is considered that the intent f of this item is fulfilled. All of these documents are j available on site for NRC review." | | and station directives, it is considered that the intent f of this item is fulfilled. All of these documents are j available on site for NRC review." |
| l In response, the NRC by a letter dated April 7, 1980, provided the Staff's evaluation of Duke's submittal on this subject: | | l In response, the NRC by a {{letter dated|date=April 7, 1980|text=letter dated April 7, 1980}}, provided the Staff's evaluation of Duke's submittal on this subject: |
| [ | | [ |
| l "2.2.1.a Shift Supervisor Responsibilities _ | | l "2.2.1.a Shift Supervisor Responsibilities _ |
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| [ | | [ |
| '~ | | '~ |
| interpretation of intent. In support, Duke cites the " Draft commission policy statement on Engineering Expertise on Shift" published in the Federal Register on July 25, 1983, which proposes a policy to allow licensees to combine the SRO and STA functions. In addition, Duke is aware that Boston Edison Company submitted, by a June 20, 1984 letter, an amendment request to include an additional footnote to a technical specification table which would indicate that a STA with a SRO License may serve simultaneously as a STA and | | interpretation of intent. In support, Duke cites the " Draft commission policy statement on Engineering Expertise on Shift" published in the Federal Register on July 25, 1983, which proposes a policy to allow licensees to combine the SRO and STA functions. In addition, Duke is aware that Boston Edison Company submitted, by a {{letter dated|date=June 20, 1984|text=June 20, 1984 letter}}, an amendment request to include an additional footnote to a technical specification table which would indicate that a STA with a SRO License may serve simultaneously as a STA and |
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| t SRO (Vol 49, No. 164 FR 33356). This indicates apparent acceptability of a combined SRO/STA program, and thus, no basis for the alleged violation. | | t SRO (Vol 49, No. 164 FR 33356). This indicates apparent acceptability of a combined SRO/STA program, and thus, no basis for the alleged violation. |
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| The following excerpt from the order concerns this NUREG-0737 item: | | The following excerpt from the order concerns this NUREG-0737 item: |
| "I.A.1.3.1 Limit Overtime This item was acceptably resolved by the November 2, 1981, NRC letter to the licensee. However, Generic Letter 82-12, issued June 15, 1982, slightly revised the Commission's policy statement of February 8, 1982r'and requested that licensee review their past actions to assure that the administrative section of the Technical Specifications be revised to assure that plant administrative procedures follow the revised working hour guidelines. The licensee's response of July 23, 1982, 'strongly supports the overall thrust of controlling the working hours of employees here to the extent of pre-venting a compromise of safety", endorses the ANS 3.2 draft on this subject and, "strongly objects to the proposed action specified with respect to its being included in Technical Specifications". This issue is being reviewed by the Staf f." | | "I.A.1.3.1 Limit Overtime This item was acceptably resolved by the November 2, 1981, NRC letter to the licensee. However, Generic Letter 82-12, issued June 15, 1982, slightly revised the Commission's policy statement of February 8, 1982r'and requested that licensee review their past actions to assure that the administrative section of the Technical Specifications be revised to assure that plant administrative procedures follow the revised working hour guidelines. The licensee's response of July 23, 1982, 'strongly supports the overall thrust of controlling the working hours of employees here to the extent of pre-venting a compromise of safety", endorses the ANS 3.2 draft on this subject and, "strongly objects to the proposed action specified with respect to its being included in Technical Specifications". This issue is being reviewed by the Staf f." |
| b) In a letter dated November 2, 1981 from NRC/0NRR to Duke Power Company, several NUREG-0737 Items were addressed. For Item | | b) In a {{letter dated|date=November 2, 1981|text=letter dated November 2, 1981}} from NRC/0NRR to Duke Power Company, several NUREG-0737 Items were addressed. For Item |
| * 1.A.1.3, the following conclusions were given: | | * 1.A.1.3, the following conclusions were given: |
| " Duke Power Company's (Duke's) December 15, 1980 letter ... | | " Duke Power Company's (Duke's) {{letter dated|date=December 15, 1980|text=December 15, 1980 letter}} ... |
| stated that administrative procedures had been implemented ... l | | stated that administrative procedures had been implemented ... l |
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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20211B7881999-08-10010 August 1999 Transmits Summary of Two Meetings with Risk-Informed TS Task Force in Rockville,Md on 990514 & 0714 ML20209H6921999-07-15015 July 1999 Forwards Comments on Preliminary Accident Sequence Precursor Analysis Provided in NRC Re Operational Condition Reported in LER 269/1998-04 ML20195H1681999-06-10010 June 1999 Forwards Copy of Preliminary ASP Analysis of Operational Condition Discovered at Ons,Units 1,2 & 3 on 980212 & Reported in LER 269/98-004,for Review & Comment ML20207C0321999-05-18018 May 1999 Forwards Fifth Rept Which Covers Month of Apr 1999. Commission Approved Transfer of TMI-1 Operating License from Gpu to Amergen & Transfer of Operating License for Pilgrim Station from Beco to Entergy Nuclear Generating Co ML20206E4101999-04-26026 April 1999 Forwards Four Copies of Rev 9 Todpc Nuclear Security & Contingency Plan,Per 10CFR50.54(p)(2).Changes Do Not Decrease Safeguards Effectiveness of Plan.Encl Withheld,Per 10CFR73.21 ML20205T1301999-04-0909 April 1999 Informs That on 990317,C Efin & Ho Christensen Confirmed Initial Operator Licensing Exam Schedule for Y2K.Initial Exam Dates Scheduled for Wks of 000710 & 17 for Approx 13 Candidates ML20205B0571999-03-24024 March 1999 Informs That Author Determined That Partial Exemption from 10CFR170 Fee Requirements Appropriate for Footnote 4 of Review of License Renewal Application for Ons,Units 1,2 & 3, That Staff Determines Has Generic Value to Industry ML20207C0501999-02-25025 February 1999 Submits Annual Rept Specifying Quantity of Each of Principal Radionuclides Released to Environment in Liquid & Gaseous Effluents,Per 10CFR72.44(d)(3).Effluent Release from ISFSI for CY98 Was Zero ML20202H7621999-01-28028 January 1999 Discusses Guidance Re License Renewal for Operating Power Reactors Developed in Response to FY99 Energy & Water Development Appropriations Act Rept 105-581 ML20202J1901999-01-28028 January 1999 Discusses License Renewal for Operating Power Reactors.Two Applications Received for Renewing Operating Licenses. Commission Established Adjudicatory Schedule Aimed at Completing License Renewal Process in 30-36 Months ML20198S8721999-01-0707 January 1999 Responds to Message to Marks Re Info Request on Appeal Deadline & Desire to Serve Appeal Either by e-mail or by Alternative Regular Mail ML20198Q8871999-01-0707 January 1999 Responds to to Chairman SA Jackson Re Issues for Consideration for Commission During Oconee License Renewal Process.Commissioners Must Remain Impartial During Pendency of Case.Copy of Order LBP-98-33 Encl.Served on 990107 ML20198Q8971998-12-17017 December 1998 Expresses Concerns Re License Renewal of Duke Energy,Oconee Nuclear Station,Units 1,2 & 3.Commends NRC on Steps Agency Has Undertaken to Conclude Renewal Process.With Certificate of Svc.Served on 990107 05000269/LER-1998-012, Forwards LER 98-012-01,re RB Spray Pumps Being Declared Inoperable Due to Npsh.Rept Has Been Revised to Indicate Results of Testing & Corrective Actions Taken to Date1998-12-0303 December 1998 Forwards LER 98-012-01,re RB Spray Pumps Being Declared Inoperable Due to Npsh.Rept Has Been Revised to Indicate Results of Testing & Corrective Actions Taken to Date 05000269/LER-1998-013, Forwards LER 98-013-00 Re Condition Prohibited by Ts,Per 10CFR50.73(a)(1)(d).Circumstances & Causes for Event Have Not Been Fully Determined & Will Be Provided in Supplemental LER on or Before 9812021998-11-0202 November 1998 Forwards LER 98-013-00 Re Condition Prohibited by Ts,Per 10CFR50.73(a)(1)(d).Circumstances & Causes for Event Have Not Been Fully Determined & Will Be Provided in Supplemental LER on or Before 981202 ML20155D2651998-10-23023 October 1998 Expresses Appreciation for Supporting Commission Initiative in Issuing Recent Statement of Policy on Conduct of Adjudicatory Proceedings.Case-specific Orders Were Issued in Calvert Cliffs & Oconee License Renewal Proceedings ML20155B1481998-10-21021 October 1998 Informs That as Result of Discussion of Issues Re Recent Events in Ice Condenser Industry,Ice Condenser Mini-Group (Icmg),Decided to Focus Efforts on Review & Potential Rev of Ice condenser-related TS in Order to Clarify Issues ML20154B9421998-09-30030 September 1998 Amends Chattooga River Watershed Coalition Petition to Intervene in Proceedings Re Application of Duke Energy Corp to Renew OLs for Oconee Nuclear Station,Units 1,2 & 3 ML20154A8971998-09-30030 September 1998 Requests That Submitted Info Be Attached to Amends to Petition to Intervene in Proceedings Re Application of Duke Energy Corp to Renew Operating Licenses for Units 1,2 & 3 ML20153H6881998-09-27027 September 1998 Requests Consideration of Motion to Enlarge Time Required to Submit Amended Petition to Intervene in Proceeding Re Application of Duke Energy Corp to Renew OLs for Facilities ML20153E4721998-09-24024 September 1998 Forwards Notices of Appearances for Attorneys Representing Duke Energy Corp,Applicant in Proceeding for License Renewal of Oconee Units 1,2 & 3.With Certificate of Svc ML20153D1831998-09-17017 September 1998 Ack Receipt of of Duke Energy Co Inviting Reconsideration of Denial by NRC CFO of Duke Exemption Request from Annual Fee Requirements for General License Under 10CFR171.11(d) ML20151S7501998-08-31031 August 1998 Provides Update on Commitment Made by Licensee in Response to NOV & Imposition of Civil Penalty Re Valves in Ldst Instrument Lines That Were Incorrectly Translated Into Station Procedures ML20237B0871998-08-11011 August 1998 Informs That NRC Plans to Administer Gfes of Written Operator Licensing Exam on 981007.Sample Registration Ltr Encl ML20236V9581998-07-27027 July 1998 Forwards Corrected Pages 3.5-30b of 961211 & 3.16-2 of 970205 TS Bases.Old Amend Numbers Were Left on Pages.Rev Changes Footer on Both Pages to Reflect Bases Changes ML20236P9451998-07-15015 July 1998 Forwards Emergency Response Data Sys Implementation Documents Including Data Point Library Updates for Oconee (Number 255),Dresden (Number 257) & Susquehanna (Number 258) ML20153D1961998-07-0909 July 1998 Requests NRC Reconsider & Grant Util Request for Exemption from Duplicative License Fee Under 10CFR171.11(d) for Storage of Spent Nuclear Fuel at Oconee Nuclear Station ML20236J9871998-06-24024 June 1998 First Final Response to FOIA Request for Documents.Documents Listed in App a Already Available in Pdr.Documents Listed in App B Being Released in Entirety ML20247G0881998-05-14014 May 1998 Provides Rev 2 to Section 3.3, Instrumentation, in Support of TS-362 Amend Request.Position on Testing of Analog Trip Type Instruments W/Regard to Transition from CTS to ITS, Restated.Summary Description of Its/Bases Changes,Encl 05000269/LER-1998-002, Forwards LER 98-002-01 Re non-isolable Weld Leak on Pressurizer Surge Line Drain Pipe Which Resulted in Unit Shutdown1998-04-30030 April 1998 Forwards LER 98-002-01 Re non-isolable Weld Leak on Pressurizer Surge Line Drain Pipe Which Resulted in Unit Shutdown ML20217G0351998-03-26026 March 1998 Submits Ltr to Update Commitment Made by Oconee in Response to Subject Violation.Update Assures That Details of Particular CA Are Appropriately Contained in Docketed Correspondence ML20203J9301998-02-26026 February 1998 Submits Response to NRC Bulletin 88-008, Thermal Stresses in Piping Connected to Rcs. Suppl 1 to Bulletin Attached & Contains Listed Commitments ML20199J7441998-02-0202 February 1998 Responds to NRC Bulletin 96-004 for NUHOMS-24P Sf Storage Sys Used at Plant Site.Nrc Reviewed Response & Found Response to Be Acceptable ML20198K9321998-01-13013 January 1998 Ack Receipt of Requesting Exemption from 10CFR171 for ISFSI License SNM-2503 & General License Provisions of 72.214 ML20198M9361998-01-12012 January 1998 Responds to Request That rept,BAW-2303P,rev 3 Be Considered Exempt from Mandatory Public Disclosure.Determined That Info Sought to Be Withheld Contains Proprietary Commercial Info & Will Be Withheld from Public Disclosure ML20203C8481997-12-10010 December 1997 Forwards Emergency Response Data Sys Implementation Documents for Plants.W/O Encl 05000269/LER-1997-003, Forwards LER 97-003-01 Re post-LOCA Boron Dilution Design Basis Not Being Met.Rept Includes Updated Info & Revised Corrective Action1997-11-12012 November 1997 Forwards LER 97-003-01 Re post-LOCA Boron Dilution Design Basis Not Being Met.Rept Includes Updated Info & Revised Corrective Action ML20198Q5741997-11-0303 November 1997 Provides Suppl to Initial 971020 Application for Amend to TS Re SG Tubing Surveillance Requirements,In Response to NRC 971030 Request for Addl Info.Proprietary Rev 3 to BAW-2303P, OTSG Repair Roll Qualification Rept Encl.Rept Withheld ML20211P1591997-10-17017 October 1997 Ack Receipt of & Check for $330,000 in Payment for Civil Penalty.Corrective Actions Will Be Examined During Future Insp ML20217D7261997-10-0101 October 1997 Informs That Staff Intends to Use Working Draft SRP-LR as Aid in Reviewing License Renewal Submittals Received from Dpc,Other Licensees & Owners Groups.Policy Issues Will Be Referred to Commission for Resolution ML20211F7981997-09-25025 September 1997 Submits Response to Violations Noted in Insp Repts 50-269/97-10,50-270/97-10 & 50-287/97-10 & Proposed Imposition of Civil Penalty in Amount of $330,000.Corrective Actions:Ldst Instrument Mods on All Three Units Completed ML20217D9341997-09-22022 September 1997 Informs That NRC Staff Has Accepted Deferral of Completion of Certain Actions Requested by Bulletin 96-03, Potential of Plugging of ECCS Strainers by Debris in Boiling Water Reactor ML20211C8021997-09-18018 September 1997 Forwards Revised TS Amend Re Reactor Bldg Structural Integrity.Previously Submitted TSs Contained Editorial Error ML20210T7121997-09-0404 September 1997 Informs That Representatives from Oconee Who Compose LERs Would Like to Meet W/Staff & AEOD at Convenient Place & Time to Facilitate Process.Concerns Addressed in Encl ML20216G5821997-09-0404 September 1997 Informs That 970730 Submittal Re Oconee Nuclear Station, Units 1,2 & 3 Will Be Marked Proprietary & Being Withheld Per 10CFR2.790(b)(5) & Section 103(b) of AEC Act of 1954 IR 05000269/19970071997-08-27027 August 1997 Discusses Insp Repts 50-269/97-07,50-270/97-07,50-287/97-07, 50-269/97-08,50-270/97-08 & 50-287/97-08 on 970606 & Forwards Notice of Violation & Proposed Imposition of Civil Penalty in Amount of $330,000 ML20210N1531997-08-13013 August 1997 Confirms 970807 Telcon Between J Burchfield & R Carroll Re Management Meeting to Be Conducted at Oconee Nuclear Station on 970922.Purpose of Meeting to Discuss Oconee Emergency Power Project Initiatives ML20210M8381997-08-13013 August 1997 Confirms Conversation Between J Burchfield & R Carroll on 970807 Re Mgt Meeting to Be Conducted in Region II Ofc on 971113.Meeting to Discuss Status of Plant Performance Improvement Initiatives ML20210N1121997-08-12012 August 1997 Informs That NRC Plans to Administer Generic Fundamentals Exam Section of Written Operator Licensing Exam on 971008. Facililty Must Submit Either Ltr Indicating No Candidates Scheduled to Participate or Listing Names of Candidates ML20149J4841997-07-21021 July 1997 Forwards Addl Pages to Rev 5 to Duke Power Co Nuclear Security & Contingency Plan. Encl Withheld 1999-08-10
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARML20209H6921999-07-15015 July 1999 Forwards Comments on Preliminary Accident Sequence Precursor Analysis Provided in NRC Re Operational Condition Reported in LER 269/1998-04 ML20206E4101999-04-26026 April 1999 Forwards Four Copies of Rev 9 Todpc Nuclear Security & Contingency Plan,Per 10CFR50.54(p)(2).Changes Do Not Decrease Safeguards Effectiveness of Plan.Encl Withheld,Per 10CFR73.21 ML20207C0501999-02-25025 February 1999 Submits Annual Rept Specifying Quantity of Each of Principal Radionuclides Released to Environment in Liquid & Gaseous Effluents,Per 10CFR72.44(d)(3).Effluent Release from ISFSI for CY98 Was Zero ML20198Q8971998-12-17017 December 1998 Expresses Concerns Re License Renewal of Duke Energy,Oconee Nuclear Station,Units 1,2 & 3.Commends NRC on Steps Agency Has Undertaken to Conclude Renewal Process.With Certificate of Svc.Served on 990107 05000269/LER-1998-012, Forwards LER 98-012-01,re RB Spray Pumps Being Declared Inoperable Due to Npsh.Rept Has Been Revised to Indicate Results of Testing & Corrective Actions Taken to Date1998-12-0303 December 1998 Forwards LER 98-012-01,re RB Spray Pumps Being Declared Inoperable Due to Npsh.Rept Has Been Revised to Indicate Results of Testing & Corrective Actions Taken to Date 05000269/LER-1998-013, Forwards LER 98-013-00 Re Condition Prohibited by Ts,Per 10CFR50.73(a)(1)(d).Circumstances & Causes for Event Have Not Been Fully Determined & Will Be Provided in Supplemental LER on or Before 9812021998-11-0202 November 1998 Forwards LER 98-013-00 Re Condition Prohibited by Ts,Per 10CFR50.73(a)(1)(d).Circumstances & Causes for Event Have Not Been Fully Determined & Will Be Provided in Supplemental LER on or Before 981202 ML20155B1481998-10-21021 October 1998 Informs That as Result of Discussion of Issues Re Recent Events in Ice Condenser Industry,Ice Condenser Mini-Group (Icmg),Decided to Focus Efforts on Review & Potential Rev of Ice condenser-related TS in Order to Clarify Issues ML20154B9421998-09-30030 September 1998 Amends Chattooga River Watershed Coalition Petition to Intervene in Proceedings Re Application of Duke Energy Corp to Renew OLs for Oconee Nuclear Station,Units 1,2 & 3 ML20154A8971998-09-30030 September 1998 Requests That Submitted Info Be Attached to Amends to Petition to Intervene in Proceedings Re Application of Duke Energy Corp to Renew Operating Licenses for Units 1,2 & 3 ML20153H6881998-09-27027 September 1998 Requests Consideration of Motion to Enlarge Time Required to Submit Amended Petition to Intervene in Proceeding Re Application of Duke Energy Corp to Renew OLs for Facilities ML20153E4721998-09-24024 September 1998 Forwards Notices of Appearances for Attorneys Representing Duke Energy Corp,Applicant in Proceeding for License Renewal of Oconee Units 1,2 & 3.With Certificate of Svc ML20151S7501998-08-31031 August 1998 Provides Update on Commitment Made by Licensee in Response to NOV & Imposition of Civil Penalty Re Valves in Ldst Instrument Lines That Were Incorrectly Translated Into Station Procedures ML20236V9581998-07-27027 July 1998 Forwards Corrected Pages 3.5-30b of 961211 & 3.16-2 of 970205 TS Bases.Old Amend Numbers Were Left on Pages.Rev Changes Footer on Both Pages to Reflect Bases Changes ML20153D1961998-07-0909 July 1998 Requests NRC Reconsider & Grant Util Request for Exemption from Duplicative License Fee Under 10CFR171.11(d) for Storage of Spent Nuclear Fuel at Oconee Nuclear Station ML20247G0881998-05-14014 May 1998 Provides Rev 2 to Section 3.3, Instrumentation, in Support of TS-362 Amend Request.Position on Testing of Analog Trip Type Instruments W/Regard to Transition from CTS to ITS, Restated.Summary Description of Its/Bases Changes,Encl 05000269/LER-1998-002, Forwards LER 98-002-01 Re non-isolable Weld Leak on Pressurizer Surge Line Drain Pipe Which Resulted in Unit Shutdown1998-04-30030 April 1998 Forwards LER 98-002-01 Re non-isolable Weld Leak on Pressurizer Surge Line Drain Pipe Which Resulted in Unit Shutdown ML20217G0351998-03-26026 March 1998 Submits Ltr to Update Commitment Made by Oconee in Response to Subject Violation.Update Assures That Details of Particular CA Are Appropriately Contained in Docketed Correspondence ML20203J9301998-02-26026 February 1998 Submits Response to NRC Bulletin 88-008, Thermal Stresses in Piping Connected to Rcs. Suppl 1 to Bulletin Attached & Contains Listed Commitments 05000269/LER-1997-003, Forwards LER 97-003-01 Re post-LOCA Boron Dilution Design Basis Not Being Met.Rept Includes Updated Info & Revised Corrective Action1997-11-12012 November 1997 Forwards LER 97-003-01 Re post-LOCA Boron Dilution Design Basis Not Being Met.Rept Includes Updated Info & Revised Corrective Action ML20198Q5741997-11-0303 November 1997 Provides Suppl to Initial 971020 Application for Amend to TS Re SG Tubing Surveillance Requirements,In Response to NRC 971030 Request for Addl Info.Proprietary Rev 3 to BAW-2303P, OTSG Repair Roll Qualification Rept Encl.Rept Withheld ML20211F7981997-09-25025 September 1997 Submits Response to Violations Noted in Insp Repts 50-269/97-10,50-270/97-10 & 50-287/97-10 & Proposed Imposition of Civil Penalty in Amount of $330,000.Corrective Actions:Ldst Instrument Mods on All Three Units Completed ML20211C8021997-09-18018 September 1997 Forwards Revised TS Amend Re Reactor Bldg Structural Integrity.Previously Submitted TSs Contained Editorial Error ML20210T7121997-09-0404 September 1997 Informs That Representatives from Oconee Who Compose LERs Would Like to Meet W/Staff & AEOD at Convenient Place & Time to Facilitate Process.Concerns Addressed in Encl ML20149J4841997-07-21021 July 1997 Forwards Addl Pages to Rev 5 to Duke Power Co Nuclear Security & Contingency Plan. Encl Withheld ML20141F1381997-06-25025 June 1997 Forwards Rev 4 to Nuclear Security Training & Qualification Plan, Per 10CFR50.4 ML20140C9531997-06-0303 June 1997 Requests NRC Approval of Amend to Oconee ISFSI to Obtain Commission Approval of Proposed Rev 6 to Encl Physical Security Plan.W/O Encls ML20148C8621997-05-22022 May 1997 Informs That TR BAW-2241P Will Be Ref in Future Submittals of P/T Limit Curve Revs for B&W Plants as Result of 970519 Telcon Between L Lois & J Taylor ML20141K1981997-05-19019 May 1997 Forwards Rev 6 to Duke Power Co Nuclear Security & Contingency Plan.Encl Withheld,Per 10CFR73.21 ML20138G8981997-04-30030 April 1997 Forwards Rev 5 to DPC Security & Contingency Plan.Encl Withheld ML20138B3421997-04-22022 April 1997 Submits Response to Request for Addl Info Re Proposed Amend to Reactor Bldg Structural Integrity Tech Specs.Info Provided in Attachments 2 & 3 Supersedes Revised Pages & Markup Pages in Attachment 1 & 2,respectively ML20137N0231997-03-26026 March 1997 Forwards Revised TS 3.1.6 Bases Pages Deleting Detection Time of Reactor Bldg Air Particulate Monitor for RCS Leak of 1 Gpm ML20137B4731997-03-12012 March 1997 Forwards Rev 3 to Security Training & Qualification Plan.Rev Withheld,Per 10CFR73.21 ML20134P3831997-02-18018 February 1997 Submits Clarification of Design Basis Requirements at ONS for Permanently Installed Insulation in Response to NRC Bulletin 93-002, Debris Plugging of Emergency Core Cooling Suction Strainers ML20138L2101997-02-14014 February 1997 Forwards Monthly Operating Repts for Jan 1997 for Oconee Nuclear Station,Units 1,2 & 3 & Revised Monthly Operating Status Repts for Dec 1996 ML20134G5511997-02-0404 February 1997 Requests Exemption to Requirements of 10CFR70.24 Re Criticality Accident Monitoring,Per 10CFR70.14(a) & 70.24(d) ML20133M5971997-01-13013 January 1997 Forwards Revs to Oconee Selected Licensee Commitments Manual ML20138G8411996-12-26026 December 1996 Submits Supplementatl Info Re Emergency Power Engineered Safeguards Functional Test Amend Request ML20132F0911996-12-17017 December 1996 Forwards Response to 961212 & 13 Telcons Re Amend to Licenses for Proposed Changes to Updated Final Safety Analysis Rept Re one-time Emergency Power Engineered Safeguards Functional Test 05000269/LER-1996-008, Forwards Suppl to LER 96-008 Concerning Missed Valve Surveillance Which Resulted in Borated Water Storage Tank Technical Inoperability1996-10-31031 October 1996 Forwards Suppl to LER 96-008 Concerning Missed Valve Surveillance Which Resulted in Borated Water Storage Tank Technical Inoperability ML20134H2231996-10-30030 October 1996 Forwards Revised TS 3.7 Bases,Indicating Info Deleted ML20129B2571996-10-16016 October 1996 Submits Addl Info Re 960220 Application for Amends to Licenses DPR-38,DPR-47 & DPR-55 Concerning Proposed Rev to Chemistry TS Sections 3.1.5,3.1.10 & 4.1,in Response to NRC Telcon Request.Revised TS Pages Encl ML20128H2731996-09-19019 September 1996 Forwards Public Version of Rev 96-06 to Plant Emergency plan.W/961003 Release Memo ML20117D5691996-08-23023 August 1996 Requests Exemption for Ons,Units 1 & 2 & Cns,Units 1 & 2 Iaw/Provisions of 10CFR73.5, Requirements for Physical Protection of Licensed Activities in Nuclear Power Reactors Against Radiological Sabotage ML20116F0051996-08-0101 August 1996 Forwards Corrected Page for Proposed Amend to TS Re Removal of Es Signal from Valves LPSW-4 & LPSW-5 ML20117E6031996-06-26026 June 1996 Forwards Public Version of Change 2 to RP/0/B/1000/01, Emergency Classification & Change 4 to RP/0/B/1000/22, Procedures for Site Fire Damage Assessment & Repair ML20112A0581996-05-14014 May 1996 Responds to NRC Bulletin 96-002, Movement of Heavy Loads Over Spent Fuel,Over Fuel in Reactor Core or Over Safety-Related Equipment ML20115C4371996-05-13013 May 1996 Responds to NRC Bulletin 96-02, Movement of Heavy Loads Over Spent Fuel,Over Fuel in Reactor Core,Or Over Safety-Related Equipment, ML20117D4931996-04-24024 April 1996 Submits Clarification of Reporting Requirements Under 10CFR50.72(b)(2)(vi) ML20107K4991996-04-19019 April 1996 Forwards Rev 2 to Security Training & Qualification Plan. Changes Identified in Rev 2 Do Not Decrease Effectiveness of Plan & Thereby Submitted,Per 10CFR50.54(p),(2).Rev Withheld, Per 10CFR73.21 ML20107K5361996-04-18018 April 1996 Forwards Rev 4 to Util Security & Contingency Plan 1999-07-15
[Table view] Category:UTILITY TO NRC
MONTHYEARML16259A2391990-08-22022 August 1990 Forwards Public Version of Rev 27 to Company Crisis Mgt Implementing Procedure CMIP-2, News Group Plan. W/ Dh Grimsley 900906 Release Memo ML20059C1201990-08-20020 August 1990 Forwards Rept Summarizing Util Findings Re Three False Negative Blind Performance Urine Drug Screens Which Occurred During Jan & Feb 1990.Recommends That NRC Consider Generic Communication to Clearly State Reporting Requirement ML20063Q2671990-08-14014 August 1990 Forwards Public Version of Revised Crisis Mgt Implementing Procedures,Including Rev 36 to CMIP-1,Rev 32 to CMIP-4,Rev 36 to CMIP-5,Rev 41 to CMIP-6,Rev 40 to CMIP-7,Rev 27 to CMIP-8 & Rev 35 to CMIP-9.W/DH Grimsley 900821 Release Memo ML20055C9851990-06-25025 June 1990 Forwards Rev 9 to Training & Qualification Plan.Rev Withheld ML16152A9841990-06-19019 June 1990 Forwards Revised Public Version of Rev 90-03 to Vol B of Epips,Including CP/2/A/2002/04C, Operating Procedure for Post-Accident Liquid Sampling, & Maint Directive 8.1 ML20044A4491990-06-14014 June 1990 Forwards Public Version of Rev 90-05 to Vol C to EPIP Manual. W/Dh Grimsley 900627 Release Memo ML16152A9821990-06-14014 June 1990 Forwards Public Version of Rev 90-02 to Vol B to Oconee Nuclear Station Epips. W/Dh Grimsley 900627 Release Memo ML20043E2571990-05-31031 May 1990 Forwards Request for Relief 90-01 from Requirements of Section XI of ASME Boiler & Pressure Vessel Code Re Inservice Insp During Second 10-yr Interval ML20043F4761990-05-30030 May 1990 Forwards Public Version of Revised Crisis Mgt Implementing Procedures,Consisting of Rev 20 to CMIP-13 & Deletion of CMIP-15 & CMIP-17.W/900612 Release Memo ML20043A5441990-05-16016 May 1990 Discusses Status of Safety & Performance Improvement Program Portion of B&W Owners Group EOP Review Project ML16152A9621990-05-0909 May 1990 Forwards Public Version of Revised Crisis Mgt Implementing Procedures,Including Rev 35 to CMIP-1,Rev 26 to CMIP-2,Rev 31 to CMIP-4,Rev 35 to CMIP-5,Rev 40 to CMIP-6,Rev 39 to CMIP-7 & Rev 26 to CMIP-8.W/DH Grimsley 900517 Release Memo ML16152A9531990-05-0202 May 1990 Forwards Proprietary DPC-NE-2000P-A & Nonproprietary DPC-NE-2000-A, DCHF-1 Correlation for Predicting Heat Flux in Mixing Vane Grid Fuel Assemblies. Proprietary Rept Withheld ML20042H0321990-04-30030 April 1990 Forwards Public Version of Rev 90-04 to Vol C to EPIP Manual ML15217A1051990-03-26026 March 1990 Forwards Revised 1989 Annual Radiological Environ Operating Rept,Consisting of Revised Pages Summarizing Annual Liquid Dose Calculations ML20012D6941990-03-21021 March 1990 Advises of No Human Engineering Discrepancy Mods of Safety Significance for Overall Operation of Plant,Per 880420 Commitment ML16152A9411990-03-14014 March 1990 Forwards Public Version of Rev 90-01 (Vol a) to Emergency Plan Manual & Revs 90-01 (Vol B) & 90-03 (Vol C) to EPIP Manual.W/Dh Grimsley 900329 Release Memo ML20012B3741990-03-0101 March 1990 Requests Extension to Respond to Generic Ltr 90-01 Re Participation in Regulatory Impact Survey Until 900402.Util in Process of Completing Questionnaires for All Units ML15217A1031990-02-28028 February 1990 Forwards Semiannual Radioactive Effluent Release Rept for Jul-Dec 1989 for McGuire Nuclear Station Units 1 & 2 & Revised Process Control Programs & Offsite Dose Calculation Manuals ML20012B4541990-02-21021 February 1990 Forwards Public Version of Vol C to Rev 90-02 to EPIP Manuals ML20012B3661990-02-21021 February 1990 Forwards Rev 1 to Cycle 12 Reload Rept,Changing Assumed RCS Flow & Correcting Typo ML20012B1691990-02-19019 February 1990 Forwards Public Version of Crisis Mgt Implementing Procedures,Including Rev 34 to CMIP-1,Rev 25 to CMIP-2, Rev 30 to CMIP-4,Rev 34 to CMIP-5,Rev 39 to CMIP-5 & Rev 38 to CMIP-7 ML19354E6711990-01-24024 January 1990 Requests Approval to Use Alloy 690 Plugs as Alternative to Requirements of 10CFR55(a),codes & Stds for Plants Prior to 900226 ML20006C7181990-01-22022 January 1990 Forwards Rev 30 to Security Plan.W/O Encl ML16152A9061990-01-19019 January 1990 Forwards Public Version of Rev 90-01 to Vol C to Oconee Nuclear Station Implementing Procedures Emergency Plan & Rev 89-03 to Vol a to Oconee Nuclear Station Emergency Plan. W/900131 Release Memo ML16152A9091990-01-18018 January 1990 Forwards Public Version of Rev 33 to Crisis Mgt Implementing Procedure CMIP-1, Recovery Manager & Immediate Staff & Rev 24 to CMIP-2, News Group Plan. W/900131 Release Memo ML20005G7601990-01-0404 January 1990 Forwards Public Version of Rev 33 to Crisis Mgt Plan. Privacy Info Should Be Deleted Prior to Placement in Pdr.W/ D Grimsley 900118 Release Memo ML20005G1181990-01-0404 January 1990 Forwards Response to NRC Recommendations in 890828 Audit Evaluation Rept Re Safety & Performance Improvement Program. Util Fully Committed to Enacting Recommendations from Program Via B&W Owners Group Improvement Program ML20042D3731990-01-0202 January 1990 Forwards Revised Crisis Mgt Implementing Procedures, Including Rev 32 to CMIP-1,Rev 29 to CMIP-4,Rev 33 to CMIP-5,Rev 38 to CMIP-6,Rev 37 to CMIP-7,Rev 32 to CMIP-9, Rev 1 to CMIP-14 & Rev 30 to CMIP-21 ML19351A5721989-12-0707 December 1989 Withdraws Commitment to Install Cavitating Venturies or Any Other Mod to Relieve Operator Burden in Ensuring That Emergency Feedwater Pumps Protected from Runout in Postulated Accidents W/Low Steam Generator Pressurization ML20011D2411989-11-30030 November 1989 Forwards Revised Crises Mgt Implementing Procedures, Including Rev 23 to CMIP-2 & Rev 3 to CMIP-15 ML16152A8751989-11-21021 November 1989 Forwards Proprietary DPC-NE-2003P-A & Nonproprietary DPC-NE-2003-A, Core Thermal-Hydraulic Methodology Using VIPRE-01. Proprietary Rept Withheld ML19332C6571989-11-20020 November 1989 Advises That Listed Addl Protective Measures Will Be Provided for Auxiliary Svc Water Piping,Per 890530 Ltr ML16152A8731989-11-0101 November 1989 Forwards Public Version of Revised Crisis Mgt Implementing Procedures,Including Rev 31 to CMIP-1,Rev 28 to CMIP-4,Rev 32 to CMIP-5,Rev 37 to CMIP-6,Rev 36 to CMIP-7,Rev 25 to CMIP-8 & Rev 31 to CMIP-9.W/891020 Release Memo ML16152A8701989-10-30030 October 1989 Forwards Public Version of Rev 32 to Crisis Mgt Plan for Nuclear Stations. W/891113 Release Memo ML16152A8641989-10-18018 October 1989 Forwards Public Version of Revs 89-05 & 89-07 to Vol B & C, Respectively,Of Implementing Procedures Emergency Plan. W/891030 Release Memo ML19351A2771989-10-13013 October 1989 Advises That Tech Spec Amend Request,Including Revised 15 EFPY Pressure/Temp Limits & Revised Low Temp Overpressure Protection Sys Operability Requirements Will Be Submitted by 891115,per Commitment in 890131 Ltr Re Generic Ltr 88-11 ML19325C9181989-10-0909 October 1989 Forwards Rev 8 to Training & Qualification Plan.Rev Withheld ML20248F1971989-09-29029 September 1989 Clarifies Tech Spec Rev,Consisting of Changes to App J Test Requirements for Valves CA-27,HP-155 & CF-47.All Lines Leading from Auxiliary Bldg to Valves HP-155 & CA-27 Maintained Normally Isolated Through Closed Manual Valves ML20246G9561989-08-23023 August 1989 Submits Details of Method for Reporting Findings Resulting from Design Basis Documentation Program,Per 890728 Meeting. Util Agrees to Submit LER for Each Finding Identified in Design Basis Documentation Program ML20245H4841989-08-0909 August 1989 Forwards Addl Info on DPC-NE-3000, Thermal-Hydraulic Transient Analysis Methodology, Per 890718 & 19 Telcons Re Steam Generator Heat Transfer Modeling W/Retran Code ML20245L6441989-08-0404 August 1989 Documents 890726 Conference Call Re Implementation Schedule for ATWS Mods.Proposed Schedule for Mods to Install ATWS Mitigation Sys Actuation Circuitry Based on Decision to Utilize Programmable Logic Controller ML20248C0091989-07-31031 July 1989 Advises That Response to Generic Ltr 89-06, SPDS, Will Be Delayed Due to Late Date of Receipt of Ltr.Submittal Anticipted by 890808 ML20247H4211989-07-25025 July 1989 Forwards Rev 29 to Security Plan.Rev Withheld ML20247K0211989-07-21021 July 1989 Responds to Generic Ltr 88-14, Instrument Air Supply Sys Problems Affecting Safety-Related Equipment, Clarifying Info in .Use of Unqualified Components in Vent Paths for Valves Acceptable Based on Secondary Side Cooling ML20246G1711989-07-20020 July 1989 Submits Route Info for Shipment of Eight Irradiated Fuel Rods from Oconee to B&W Lynchburg Research Ctr in Sept 1989, Consisting of Single Shipment w/NLI-1/2 Spent Fuel Shipping Cask.Approval Requested by 890901 ML20247A8991989-07-13013 July 1989 Forwards Rev 4 to Process Control Program ML20246P5721989-07-13013 July 1989 Forwards Request for Relief 89-06 from Requirement of Section of XI of ASME Boiler & Pressure Code Re Second 10-yr Interval Inservice Insp.W/Three Oversize Drawings ML20246K2101989-06-28028 June 1989 Forwards Public Version of Revised Crisis Mgt Implementing procedures.W/890711 Release Memo ML20247N9591989-05-30030 May 1989 Forwards Request for Relief 89-04 from Inservice Insp Requirements of Section XI of ASME Boiler & Pressure Vessel Code,Based on Impracticality of Performing Full Volumetric Exam of Turbine Stop Valve Upper Head to Valve Body Studs ML20247E5401989-05-15015 May 1989 Confirms 890504 Discussion Re Acceptance of Util Proposed Schedule for Implementation of ATWS Mods.Util Cannot Commit to Submitting Final Design Description Earlier than 890901 1990-08-22
[Table view] |
Text
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DUKE POWER COMihNY P.O. DOx 33180 CHARLOTTE, N.C. 28242 TE LE PHONE B. TUCKER (704) 373-4531 vice reassesev 69
=== e avi - , cemberj v., 21g a ,84, c l Mr. James P. O'Reilly, Regional Administrator U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900
}
Atlanta, Georgia 30323 l
f
Subject:
Oconee Nuclear Station IE Inspection Report Nos. 50-269/84-16 '
50-270/84-15 50-287/84-26
Dear Sir:
In response to your letter dated November 23, 1984 which transmitted the subject Inspection Report, the attached response to the cited item of non-compliance is provided. I declare under penalty of perjury that the statements set forth herein are true and correct to the best of my knowledge on December 21, 1984.
Very truly yours, C
/
h.( k.N u ' -
Hal B. Tucker SGG: sib Attachment cc: Mr. J. C. Bryant NRC Resident Inspector Oconee Nuclear Station 0
4 hoh7100011 ADOCK050320 05000269 0 PDtt
- - _ - _ _ _ _ _ _ - _ _ _ _ _ . l
Licensee 7590-01 July 10, 1981 to Oconee, Order Confirming i TM1 items to NRC order Commitments On Post TM1 Related Issues, requires d in the certa nItem I.A.1.3, be implemented. visor Responsibilities to Non-on Duty Personnel, is liste order as having been completed.
14, 1984, the administrative Contrary to the above, as of September duties of the Shift Supervisor are delegated to the Unit Supervisors in and control room Senior Reactor Operators (SR0s) who are on duty the control room.
- 1) applicable to This is a Severity Level IV violation (Supplement .
Units 1, 2, and 3.
_Re sponse_
l 1)
Admission or denial of the alleged violation:
This violation is denied for the following reasons:
7590-01 confirming Duke Power's a) Duke notes that NRC order l commitments to implement certain Post TMI related items for10, 1981, M Oconee Nuclear Station was issued Julyletter was based on Duke and July 6, 1984. The July 10, 1981 commitments made in regard to the implementation of the drequire-l ments set forth in NUREG-0737 for which The March'the18, NRC1983Staff requeste letter was l completion before June 30, 1981.
based on commitments made by Duke in response 17, 1982 and May 5,to NRC's Generic 1982, i
l Letters 82-05 and 82-10 dated MarchThe July 6, 1984 3 letter was based o respectively. commitments made in response to NRC's Generic Letter 82-3 f dated December 17, 1984.
NRC Order 7590-01 dated July 10, 1981 issued to Oconee was ,p 6 f reviewed, which revealed that TMI Item I.A.1.2, Delegating l ((,"
Administrative Shift Supervisor Responsibilities to Non-on. (
Duty Personnel, was not explicitly mentioned or listed 15, 1980 in the Duke letter :
order. However, by reference, the December The following is what appears was incorporated into the order.
within the December 15th letter concerning this NUREG-0737 L Item (I.A.l.2): 1 Status _
E [J
Item Delegate Non-Safety Shift Supervisor Duties-Complete I.A.I.2 Responsibilities in addition, Enclosure 1 to NUREG-0737 Lists Item I.A.1.2 as
" complete", but does not clarify Specific requirements of dt the Item as referenced in the Details of Section 7 of the Inspection Rep r .
Thus the violation appears to be cited against a previously 90-01.
completed requirement not explicitly documented in NRC order 75
,-2.
NUREG-0737, Item I.A.I.2 was apparently issued as a restated b) J portion of NUREG-0578 (Section 2.2.Ia), Shift Supervisor'sThis ~
1 Responsibilities.
strative the management functions responsibility that detract from or are subordinate for assuring i to fong[
the safe operat V of the plant shall be delegated to other operations personnel not on duty in the control room".
Duke Power Company by letters dated October 18 and November 21, 1979, submitted to the NRC the following response concerning )
the Shif t Supervisor responsibilities (NUREG-0578 Section 2.2.1.a :
" Appropriate directives will be reviewed and revised as necessary to fulfill the intent of this item by l
January 1, 1980."
f t
in addition, by a January 2, 1980 lettor Duke submitted to the f NRC the following:
l "The Shift Supervisor's responsibilities, as contained in f the Steam Production Administrative Policy Manual, has j
i been redefined to include several concerns of this item.
With this change, and the existing Technical Specifications I
and station directives, it is considered that the intent f of this item is fulfilled. All of these documents are j available on site for NRC review."
l In response, the NRC by a letter dated April 7, 1980, provided the Staff's evaluation of Duke's submittal on this subject:
[
l "2.2.1.a Shift Supervisor Responsibilities _
l l
l The licensee has revised the responsibilities of the Shift l Supervisor so that he can provide direct management of _
I ongoing safety related operations and not be distracted q' f from these primary responsibilities by administrative j assignments.
This revised responsibility has been set l forth in plant documents, i
f
' Based on the above considerations Verification has satisfied the requirements of this item.
we conclude d that the li, of the adequacy of the licensee's procedures will be performe by the Office of Inspection and Enforcement and will be documented in an appropriate inspection report."
In summary, Duke Power Company considers that the low d number and magnitude of the administrative' duties and functions from delegate to on-duty personnel in the control rooms do not detract or interfere with the management responsibility Additionally, for assuring the large number safe operation of the plant.
of on-duty licensed personnel further minimizes the small In fact, during the inspection exit he impact of these duties.
interview the lead inspector noted to plant management that could find no evidence that on-duty personnel were overburdened with administrative duties, as noted in the inspection report (Section 7) itself.
l
3 c) At the Exit meeting with plant management on September 14, 1984, this item was noted as an inspector concern based on not meeting the intent of NUREG-0737 guidance for delegating administrative duties. There was no mention of even a potential violation for this item. Although it was agreed at this meeting that the inspectors were to discuss some of their other findings with NRC management in Atlanta and subsequently clarify the NRC position with Oconee management via telephone, the inspectors never made the clarification call to Oconee management. Thus, the details of the inspection report are inaccurate in stating that "the inspectors informed licensee management that the inadequacy to preclude assignment of administrative duties to l on-duty personnel is a violation of Order 7590-01, which was issued under 10 CFR 2.204." ,
In conclusion, this violation is denied due to lack of evidence l that Duke Power Company has violated the letter or.intentiof any NRC order or NUREG section concerning delegation of Shift Supervision administrative duties at Oconee. The fact that no on-duty shift personnel were found to be overburdened with administrative duties supporto this contention.
- 2) Reasons for the violation:
Not applicable; see (1) above.
- 3) Corrective actions taken and results:
Not applicable; see (1) above.
- 4) Corrective actions to be taken to avoid further violations:
Not applicable; see (1) above.
l
- 5) Date when full compliance will be achieved:
l Not applicable; see (1) above.
l 8
I e
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l I
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Violation 2 Oconee Technical Specification Figure 6.1-1, Station Organization Chart, requires the Shift Technical Advisor (STA) to report to the Operating Engineer and to advise the Shift Supervisor.
Contrary to the above, as of September 14, 1984, Oconee Station Directive 3.1.36, revision dated January 18, 1984, requires the SRO/STA to report to the Shift Supervisor on items pertinent to normal operations and to perform the normal line function of SRO in charge of the control room.
f This is a Severity Level IV violation (Supplement 1) applicable to Units l 1, 2, and 3.
Response
- 1) Admission or denial of the alleged violation:
This violation is denied for the following reasons:
The Section 9 supporting details in the inspection report reflect the information contained in the cited revision of Station Directive 3.1.36 pertaining to organization and responsibilities of the SRO/STA position. This directive stated "SR0/STA will report directly to the Project Operating Engineer and not to the Shift Supervisor on items pertinent to the STA function. He will report to the Shift Supervisor on items pertinent to normal operations". Additionally, the directive stated "During off-normal events, he shall be detached from and independent of the Shif t Supervisor. During normal operation, he shall perform duties of the control Room Super-visor as directed by the Shift Supervisor".
This Station Directive has now been deleted f rom the Station Directives Manual, but the same requirements for the SRO/STA position have been transferred to Operations Management Pro-cedure 2-1 of the Operations Section Manual. 'The requirements quoted above are clearly in conformance with the interpretation of Technical Specification Figure 6.1-1 given in the violation where the STA_ reports to the Operating Engineer and advises the Shift Supervisor. Thus, Duke Power Company concludes that ,
the cited figure has not been violated, and that the information
~ ~
in the details of the Inspection Report supports this conclusion. ,
The details of the Inspection Report state that the combined v ' y I: #
t Control Room SR0/STA function does not meet the intent of NUREG-0737. Duke Power Company does not agree with this
[
'~
interpretation of intent. In support, Duke cites the " Draft commission policy statement on Engineering Expertise on Shift" published in the Federal Register on July 25, 1983, which proposes a policy to allow licensees to combine the SRO and STA functions. In addition, Duke is aware that Boston Edison Company submitted, by a June 20, 1984 letter, an amendment request to include an additional footnote to a technical specification table which would indicate that a STA with a SRO License may serve simultaneously as a STA and
t SRO (Vol 49, No. 164 FR 33356). This indicates apparent acceptability of a combined SRO/STA program, and thus, no basis for the alleged violation.
- 2) Reasons for the violation:
Not applicable; see (1) above.
- 3) Corrective actions taken and results:
Not applicable; see (1) above.
l
- 4) Corrective actions to be taken to avoid further violations:
Not applicable; see (1) above.
- 5) Date when full compliance will be achieved:
Not applicable; see (1) above.
~
violation 3 NRC ' e 7590-01, Order Confirming Licensee Commitments On Post TMI Relaced Issues Item I.A.1.3, Shift Manning, requires administrative procedures be established for the placement of overtime restrictions on plant staff who perform safety-related functions (e.g., senior reactor operators, reactor operators, health physicists, auxiliary operators, 16C technicians and key maintenance personnel).
Contrary to the above, as of September 14, 1984, Oconee Station Directive 3.1.33, revision dated January 23, 1984, does not contain provisions for limiting overtime for health physicists and key maintenance personnel.
This is a Severity Level IV violation (Supplement 1) applicable to Units .
1, 2, and 3.
Response
- 1) Admission or denial of the alleged violation:
This violation is denied for the following reasons:
a) NUREG Item I.A.1.3 required administrative procedures be established by November 1, 1980 to " develop working schedules such that use of overtime is avoided, to the extent practicable, for the plant staff who perform safety-related functions (e.g., senior reactor operators, ... health physicists, ...
and key maintenance personnel)." In response to this proposed violation, NRC order 7590-01 dated March 18, 1983 was reviewed.
The following excerpt from the order concerns this NUREG-0737 item:
"I.A.1.3.1 Limit Overtime This item was acceptably resolved by the November 2, 1981, NRC letter to the licensee. However, Generic Letter 82-12, issued June 15, 1982, slightly revised the Commission's policy statement of February 8, 1982r'and requested that licensee review their past actions to assure that the administrative section of the Technical Specifications be revised to assure that plant administrative procedures follow the revised working hour guidelines. The licensee's response of July 23, 1982, 'strongly supports the overall thrust of controlling the working hours of employees here to the extent of pre-venting a compromise of safety", endorses the ANS 3.2 draft on this subject and, "strongly objects to the proposed action specified with respect to its being included in Technical Specifications". This issue is being reviewed by the Staf f."
b) In a letter dated November 2, 1981 from NRC/0NRR to Duke Power Company, several NUREG-0737 Items were addressed. For Item
- 1.A.1.3, the following conclusions were given:
" Duke Power Company's (Duke's) December 15, 1980 letter ...
stated that administrative procedures had been implemented ... l
to limit overtime worked by plant staff who perform safety related functions. These procedures have been reviewed by NRC Inspectors and were found to meet the intent of this item."
Station administrative procedures limiting overtime have not significantly changed since this review and are therefore considered acceptable-to the NRC in meeting the requirements of NUREG-0737, Item I.A.I.3. Thus, there again is no apparent basis for the alleged violation.
c) As discussed above, guidance had been provided and is used by Station Management in the judicious use of overtime. A review of our actual practices would reveal that overtime is appropriately controlled at Oconee for all personnel. This satisfies the _
overall intent of Item I.A.I.3.
- 2) Reasons for the violation:
Not applicable; see (1) above.
( 3) Corrective actions taken and results:
l Not applicable; see (1) above.
l
- 4) Corrective actions to be taken to avoid further violations:
Not applicable; see (1) above.
- 5) Date when full compliance will be achieved:
Not applicable; see (1) above.
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