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| | number = ML20129F608 | | | number = ML20129F608 |
| | issue date = 04/19/1985 | | | issue date = 04/19/1985 |
| | title = Suppls Response to NRC 850320 Ltr Re Violations Noted in Insp Repts 50-269/84-16,50-270/84-15 & 50-287/84-26. Corrective Actions:Shift Technical Advisor (STA) Shall Rept Directly to Project Operating Engineer Re STA Function | | | title = Suppls Response to NRC Re Violations Noted in Insp Repts 50-269/84-16,50-270/84-15 & 50-287/84-26. Corrective Actions:Shift Technical Advisor (STA) Shall Rept Directly to Project Operating Engineer Re STA Function |
| | author name = Tucker H | | | author name = Tucker H |
| | author affiliation = DUKE POWER CO. | | | author affiliation = DUKE POWER CO. |
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| | contact person = | | | contact person = |
| | document report number = NUDOCS 8507170406 | | | document report number = NUDOCS 8507170406 |
| | | title reference date = 03-20-1985 |
| | document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC | | | document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC |
| | page count = 8 | | | page count = 8 |
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| ==Dear Sir:== | | ==Dear Sir:== |
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| By letter dated March 20, 1985, NRC/ Region 11 requested a supplemental response relative to the Duke response of December 21, 1984 to the notice of violation identified in the subject inspection report issued by a November 23, 1984 letter. In response, please find attached the requested supplemental response. | | By {{letter dated|date=March 20, 1985|text=letter dated March 20, 1985}}, NRC/ Region 11 requested a supplemental response relative to the Duke response of December 21, 1984 to the notice of violation identified in the subject inspection report issued by a {{letter dated|date=November 23, 1984|text=November 23, 1984 letter}}. In response, please find attached the requested supplemental response. |
| Very truly yours, | | Very truly yours, |
| / ~ b y Hal B. Tucker | | / ~ b y Hal B. Tucker |
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| This violation is denied for the reasons given below. | | This violation is denied for the reasons given below. |
| : 2) Reasons for the denial of alleged violation: | | : 2) Reasons for the denial of alleged violation: |
| Duke agrees with the NRC/ Region II specific comments provided in the letter dated March 20, 1985 regarding the intent of NUREG-0578 to prevent distraction of the Shift Supervisor by administrative duties. In addition. Duke acknowledges the correctness of the excerpt from NUREG-0578 that was quoted in the Staff Assessment of Duke's denial of Violation 1. | | Duke agrees with the NRC/ Region II specific comments provided in the {{letter dated|date=March 20, 1985|text=letter dated March 20, 1985}} regarding the intent of NUREG-0578 to prevent distraction of the Shift Supervisor by administrative duties. In addition. Duke acknowledges the correctness of the excerpt from NUREG-0578 that was quoted in the Staff Assessment of Duke's denial of Violation 1. |
| By letters dated October 18, 1979; November 21, 1979; and January 2, 1980, Duke Power made certain commitments in response to Section 2.2.Ia of NUREG-0578. In response to there submittals the NRC by a letter dated April 7,1980, provided the Staff's evaluation. | | By letters dated October 18, 1979; November 21, 1979; and January 2, 1980, Duke Power made certain commitments in response to Section 2.2.Ia of NUREG-0578. In response to there submittals the NRC by a {{letter dated|date=April 7, 1980|text=letter dated April 7,1980}}, provided the Staff's evaluation. |
| Based upon a review of these correspondences and of the commitments made. Duke contends that the NRC/ Region II has not provided any evidence indicating that Duke has violated any of its commitments that were made in response to this section of the NUREG. Duke respectfully reminds NRC/ Regia 2 II that the specifics set forth in NUREG-0578 are not binding Regulatory Requirements as are the commitments made in response to the NUREG. | | Based upon a review of these correspondences and of the commitments made. Duke contends that the NRC/ Region II has not provided any evidence indicating that Duke has violated any of its commitments that were made in response to this section of the NUREG. Duke respectfully reminds NRC/ Regia 2 II that the specifics set forth in NUREG-0578 are not binding Regulatory Requirements as are the commitments made in response to the NUREG. |
| Duke has initiated certain actions in response to the concerns expressed by the inspection team and by the NRC/ Region 11 Staff during an April 7, 1985 conference call. Duke is currently revising OMP-2-1 which defines the responsibilities of the Reactor Operator (RO) on the control board, the SRO in the control room and the STA. This action should not be interpreted to mean an an admission to the occurrence of the alleged violation. | | Duke has initiated certain actions in response to the concerns expressed by the inspection team and by the NRC/ Region 11 Staff during an April 7, 1985 conference call. Duke is currently revising OMP-2-1 which defines the responsibilities of the Reactor Operator (RO) on the control board, the SRO in the control room and the STA. This action should not be interpreted to mean an an admission to the occurrence of the alleged violation. |
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| l 2) Reasons for the violation: | | l 2) Reasons for the violation: |
| The requirements for a STA was established by NUREG-0578 and clarified by two NRC letters, dated September 13, 1979 and October 30, 1979, to all operating Nuclear Power Plants. Additional l | | The requirements for a STA was established by NUREG-0578 and clarified by two NRC letters, dated September 13, 1979 and October 30, 1979, to all operating Nuclear Power Plants. Additional l |
| clarification was provided by NUREG's 0660 and 0737. By a letter dated July 9, 1982, the NRC Staff gave interim acceptance to Oconee's SIA program, with final acceptance being withheld because some of the STA candidates didnot have a Bachelor's Degree or equivalent in a scientific or engineering discipline. | | clarification was provided by NUREG's 0660 and 0737. By a {{letter dated|date=July 9, 1982|text=letter dated July 9, 1982}}, the NRC Staff gave interim acceptance to Oconee's SIA program, with final acceptance being withheld because some of the STA candidates didnot have a Bachelor's Degree or equivalent in a scientific or engineering discipline. |
| From 1982 through 1985 negotiations took place between the NRC Staff and Duke concerning the STA program at Oconee. A NRC letter dated March 7, 1985, which approves Oconee's upgraded STA program, was issued as a result of these negotiations. The Safety Evaluation transmitted by the March 7, 1985 letter stated that; "The implementation date for the upgraded Oconee STA program is September 1, 1985. The current program will remain in effect until then." | | From 1982 through 1985 negotiations took place between the NRC Staff and Duke concerning the STA program at Oconee. A NRC {{letter dated|date=March 7, 1985|text=letter dated March 7, 1985}}, which approves Oconee's upgraded STA program, was issued as a result of these negotiations. The Safety Evaluation transmitted by the {{letter dated|date=March 7, 1985|text=March 7, 1985 letter}} stated that; "The implementation date for the upgraded Oconee STA program is September 1, 1985. The current program will remain in effect until then." |
| During the discussions preceeding the March 7, 1985 letter, Duke made certain commitments concerning the interim STA program for Oconee. Based upon Duke's understanding of the commitments made, the combining of the SR0/STA function was in compliance with these commitments. Duke didnot unilaterally and without informing the NRC modify the interim STA program. | | During the discussions preceeding the {{letter dated|date=March 7, 1985|text=March 7, 1985 letter}}, Duke made certain commitments concerning the interim STA program for Oconee. Based upon Duke's understanding of the commitments made, the combining of the SR0/STA function was in compliance with these commitments. Duke didnot unilaterally and without informing the NRC modify the interim STA program. |
| Duke acknowledges, based upon review of correspondences, that the NRC may have misunderstood how the' interim STA program is - | | Duke acknowledges, based upon review of correspondences, that the NRC may have misunderstood how the' interim STA program is - |
| structured. Please note that no attempt was made to mislead the NRC concerning the interim program. Specifically, the correspondences didnot, in no uncertain terms, explicitly describe the STA program. | | structured. Please note that no attempt was made to mislead the NRC concerning the interim program. Specifically, the correspondences didnot, in no uncertain terms, explicitly describe the STA program. |
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| : 4) Corrective actions to be taken to avoid further violations: | | : 4) Corrective actions to be taken to avoid further violations: |
| a) Operations Management Procedure 2-1, which defines the duties of the RO on the Control Board, the SRO in the Control Room, and the STA is being revised. The responsibilities of the STA will be delineated within this procedure. | | a) Operations Management Procedure 2-1, which defines the duties of the RO on the Control Board, the SRO in the Control Room, and the STA is being revised. The responsibilities of the STA will be delineated within this procedure. |
| b) Implementation of the upgraded STA program as accepted by the NRC in the March 7, 1985 letter. | | b) Implementation of the upgraded STA program as accepted by the NRC in the {{letter dated|date=March 7, 1985|text=March 7, 1985 letter}}. |
| : 5) Date when full compliance will be achieved: | | : 5) Date when full compliance will be achieved: |
| a) Revision to OMP 2-1 will be completed by May 1, 1985, b) The upgraded STA program will be implemented by September 1, 1985. | | a) Revision to OMP 2-1 will be completed by May 1, 1985, b) The upgraded STA program will be implemented by September 1, 1985. |
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| 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. | | 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 I) applicable to units 1, 2, and 3. | | This is a Severity Level IV violation (Supplement I) applicable to units 1, 2, and 3. |
| ADDITIONAL RESPONSE By the NRC/ Region II letter dated March 20, 1985, this violation was withs awn; however, it was requested that Duke provide a description of the actions planned in response to the NRC/ Region II comments relative to this item. The subsequent paragraph provides a description of the action taken to ensure that overtime restrictions for all plant Staff who perform safety-related functions are consistent with the requirements of NUREG-0737, Item I.A.1.3. | | ADDITIONAL RESPONSE By the NRC/ Region II {{letter dated|date=March 20, 1985|text=letter dated March 20, 1985}}, this violation was withs awn; however, it was requested that Duke provide a description of the actions planned in response to the NRC/ Region II comments relative to this item. The subsequent paragraph provides a description of the action taken to ensure that overtime restrictions for all plant Staff who perform safety-related functions are consistent with the requirements of NUREG-0737, Item I.A.1.3. |
| Please find enclocol, for your information, a copy of Oconee Nuclear Station Directive 2.1.5 which prescribes a program for controlling excessive working hours of station personnel. This directive applies to all personnel performing work at Oconee. | | Please find enclocol, for your information, a copy of Oconee Nuclear Station Directive 2.1.5 which prescribes a program for controlling excessive working hours of station personnel. This directive applies to all personnel performing work at Oconee. |
| J | | J |
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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
. - .
e
- k DUKE POWER GOMPANY P.O. IM)X 33180 citAHLOTTE, N.C. 2H242
- HALB. TUCKER TELEPalME ww.e. <>a4) ara->aa'
.r
- -riea" April 19,e'b6 I
19 01 Dr. J. Nelson Grace, Regional Administrator
. U. S. Nuclear Regulatory Comission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323
Subject:
Oconee Nuclear Station IE Inspection Report Nos. 50-269/84-16 50-270/84-15 50-287/84-26
Dear Sir:
By letter dated March 20, 1985, NRC/ Region 11 requested a supplemental response relative to the Duke response of December 21, 1984 to the notice of violation identified in the subject inspection report issued by a November 23, 1984 letter. In response, please find attached the requested supplemental response.
Very truly yours,
/ ~ b y Hal B. Tucker
- PFG: sib Attachment cc: Mr. J. C. Bryant-NRC Resident Inspector Oconee Nuclear Station 4
1 850717 6 850419 PDR A M 05000269 PDR, 9 '
\
1~ E o I y
VIOLATION 1 NRC Order 7590-1 July 10, 1981 to Oconee, Order Confirming Licensee Commitments On Post TMI Related Issues, requires certain TMI items to be implemented. Item 1. A.1.2, (Delegating Administrative Shif t Supervisor Responsibilities to Non-on Duty Personnel), is listed in the order as having been completed.
Contrary to the above, as of September 14, 1984, the administrative duties of the Shift Supervisor are delegated to the Unit Supervisors and control room Senior Reactor Operators (SR0s) who are on duty in the control room.
This is a Severity Level IV violation (Supplement I) applicable to units 1, 2, and 3.
ADDITIONAL RESPONSE
- 1) Admission or denial of the alleged violation:
This violation is denied for the reasons given below.
- 2) Reasons for the denial of alleged violation:
Duke agrees with the NRC/ Region II specific comments provided in the letter dated March 20, 1985 regarding the intent of NUREG-0578 to prevent distraction of the Shift Supervisor by administrative duties. In addition. Duke acknowledges the correctness of the excerpt from NUREG-0578 that was quoted in the Staff Assessment of Duke's denial of Violation 1.
By letters dated October 18, 1979; November 21, 1979; and January 2, 1980, Duke Power made certain commitments in response to Section 2.2.Ia of NUREG-0578. In response to there submittals the NRC by a letter dated April 7,1980, provided the Staff's evaluation.
Based upon a review of these correspondences and of the commitments made. Duke contends that the NRC/ Region II has not provided any evidence indicating that Duke has violated any of its commitments that were made in response to this section of the NUREG. Duke respectfully reminds NRC/ Regia 2 II that the specifics set forth in NUREG-0578 are not binding Regulatory Requirements as are the commitments made in response to the NUREG.
Duke has initiated certain actions in response to the concerns expressed by the inspection team and by the NRC/ Region 11 Staff during an April 7, 1985 conference call. Duke is currently revising OMP-2-1 which defines the responsibilities of the Reactor Operator (RO) on the control board, the SRO in the control room and the STA. This action should not be interpreted to mean an an admission to the occurrence of the alleged violation.
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 SR0/STA to report to the Shift Supervisor on items pertinent to normal operations and to perform the normal line function in SRO in charge of the control room.
This is a Severity Level IV violation (Supplement I) applicable to units 1, 2, and 3.
ADDITIONAL RESPONSE
- 1) Admission or denial of the alleged violation:
This violation is correct as stated:
l 2) Reasons for the violation:
The requirements for a STA was established by NUREG-0578 and clarified by two NRC letters, dated September 13, 1979 and October 30, 1979, to all operating Nuclear Power Plants. Additional l
clarification was provided by NUREG's 0660 and 0737. By a letter dated July 9, 1982, the NRC Staff gave interim acceptance to Oconee's SIA program, with final acceptance being withheld because some of the STA candidates didnot have a Bachelor's Degree or equivalent in a scientific or engineering discipline.
From 1982 through 1985 negotiations took place between the NRC Staff and Duke concerning the STA program at Oconee. A NRC letter dated March 7, 1985, which approves Oconee's upgraded STA program, was issued as a result of these negotiations. The Safety Evaluation transmitted by the March 7, 1985 letter stated that; "The implementation date for the upgraded Oconee STA program is September 1, 1985. The current program will remain in effect until then."
During the discussions preceeding the March 7, 1985 letter, Duke made certain commitments concerning the interim STA program for Oconee. Based upon Duke's understanding of the commitments made, the combining of the SR0/STA function was in compliance with these commitments. Duke didnot unilaterally and without informing the NRC modify the interim STA program.
Duke acknowledges, based upon review of correspondences, that the NRC may have misunderstood how the' interim STA program is -
structured. Please note that no attempt was made to mislead the NRC concerning the interim program. Specifically, the correspondences didnot, in no uncertain terms, explicitly describe the STA program.
- 3) Corrective action taken and results:
During an off-normal event the STA function will be performed by a unit supervisor from a unit other than the transient unit.
In addition, the STA shall report directly to the projects operating engineer on items pertinent to the STA function.
This will ensure that, during off-normal events, the STA will be detached and indenpendent of the normal line function of shift operation and act as an advisor to the Shift Supervisor.
- 4) Corrective actions to be taken to avoid further violations:
a) Operations Management Procedure 2-1, which defines the duties of the RO on the Control Board, the SRO in the Control Room, and the STA is being revised. The responsibilities of the STA will be delineated within this procedure.
b) Implementation of the upgraded STA program as accepted by the NRC in the March 7, 1985 letter.
- 5) Date when full compliance will be achieved:
a) Revision to OMP 2-1 will be completed by May 1, 1985, b) The upgraded STA program will be implemented by September 1, 1985.
VIOLATION 3 NRC Order 7590-01, Order Confirming Licensee Commitments On Post TMI Related Issues Item 1.A.1.3, Shift Manning, requires administrative procedures be established for the placement of overtime restrictions on plant staff who petform safety-related functions (e.g. , senior reactor operators, reactor operators, health physicists, auxiliary operators. I&C 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 I) applicable to units 1, 2, and 3.
ADDITIONAL RESPONSE By the NRC/ Region II letter dated March 20, 1985, this violation was withs awn; however, it was requested that Duke provide a description of the actions planned in response to the NRC/ Region II comments relative to this item. The subsequent paragraph provides a description of the action taken to ensure that overtime restrictions for all plant Staff who perform safety-related functions are consistent with the requirements of NUREG-0737, Item I.A.1.3.
Please find enclocol, for your information, a copy of Oconee Nuclear Station Directive 2.1.5 which prescribes a program for controlling excessive working hours of station personnel. This directive applies to all personnel performing work at Oconee.
J
~
l*A
- l ~
Oconee Nuclear Statio Directive 2.1.5 Approval b -
N$Au m Original Date k1ktkji Revised Date --
DUKE POWER COMPANY OCONEE NUCLEAR STATION m - . . . n. , q :
" ' ' ' " ' ' ' ' * ' ~
! LIMITING WORK HOURS t.
' ' ' "" ~~
i 1.0 Purpose i
i Prescribe a program for controlling excessive working hours of l station personnel.
[ 2.0 References L
i 2.1 Technical Specification 6.4.3 (Proposed) l- 2.2 NUREG 0737, Clarification of TMI Action Plan Requirements l (Item I.A.I.3)
' 2.3 NRC Generic Letter 82-12, Nuclear Power Plant Staff Working Hours, June 15, 1982 2.4 IE Circular 80-02, Nuclear Power Plant Staff Working Hours, February 1,1980 3.0 Applicability-This directive applies to all personnel performing work at the Station.
l .4.0 Responsibilities 4.1 It is the responsibility of each individual to maintain his or her work hours within the below noted guidelines.
If a situation exists or develops which will require i
deviation from the guidelines, each individual must notify his or her supervision.
'4.2 Supervisory personnel are responsible for controlling the work hours of their personnel within the below noted guidelines.. Supervisory personnel are also responsible j for obtaining the appropriate approvals to authorize
- deviation from the guidelines, i
l
. .- - . - , - - . . . . _ .-... . _. -_-. - - _ . - . . . _ - - - ~. . -
y: TJ
'k' '
. c - SD 2.1.5
. 5.0 Guidelines -
f.
5.1'.Second level management,'i.e., Coordinators Shift Supervisors, Support Engineers authorize their employees to work in excess of 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> for each employee in any I. two (2) week pay period not to exceed 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />. ;
5.2 .Section Heads may authorize their employees to work in -
excess of 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> for each employee in any two (2) week pay period not to exceed 120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br />.
i 5.3- Superintendents may authorize their employees to work in
- - excess of 120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br /> for each employee in any two (2)
- week pay period. The Station Manager will be informed of
-this authorization.
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, 5.' 4 The following requirements are applicable to employees l performing safety-related (QA' Condition -1) work. For the
[ purposes of these requirements, safety-related work is ,
- l. defined as the performance of safety-related functions i l- pursuant to "A". designated procedures. Examples of
- _ personnel who perform safety-related functions would be l Senior Reactor Operators,. Reactor Operators, Nuclear j Equipment Operators, certain Maintenance personnel, etc.
l 5.4.1 Except 'as allowed in 5.4.2 working hours shall .
! be limited as follows:
/ '
i a. An individual shall 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 j ,
shift turnover time).
4 1' b. An individual shall not be permitted to t 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 .
] 43-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 seven day period (all' excluding shift turnover time). . ,
, c. A break of at least _ eight hours shall be
- allowed between work periods (including shift. turnover' time).-
- d. Except during extended shutdown periods, the use of' overtime shall be' considered on an individual basis and not for the entire. .!
staff on shift..
.)
l 5.4.2 A deviation from 5.4.1 shall be approved by the Station Manager"(or designee). This-approval shall_be documented with the basis for granting the' deviation. Routine deviation from e s
5.4.1 is not authorized.
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.* SD 2.1.5 i
5.4.3 Time sheets (non-exempt personnel) will be reviewed to assure conformance with 5.4.1.
Supplemental pay records for exempt personnel will be reviewed to assure conformance with 5.4.1. Supervisory personnel are hereby designated to perform this review.
6.0 Documentation 6.1 No documentation is required for items 5.1, 5.2, and 5.3.
6.2 Documentation associated with 5.4.2 will be maintained available for NRC review for a period of two (2) years.
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