ML19332F079

Responds to Violations Noted in Insp Repts 50-348/89-22 & 50-364/89-22.Corrective Actions:All Managers Retrained on Intent of Overtime Procedures & Sys Established to Provide Independent Check of All Time Sheets Each Pay Period

ML19332F079
Person / Time
Site:	Farley
Issue date:	12/07/1989
From:	Hairston W ALABAMA POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 8912130369
Download: ML19332F079 (3)

Text

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,4 o Alabama Power Company 40 inverness Ccnter Parkway

. Pop' Office Der 1295

.. Birmin0 ham. Alabama 35201 Telephone r05 068 5501 W. G. Hairston,111 senior Vice President Nuclear Operations M8b3[Il3 NWCT

+ ~ tte southern electnc system December 7, 1989 p Docket Nos. 50-348 50-364 U. S. Nuclear Regulatory Comission o Attentions Document Control Desk

Washington, D. C. 20555

SUBJECT:

Reply to a Notice of Violation J. M. Farley Nuclear Plant NRC Inspection of September 11 - October 10, 1989 RE: Report Number 50-348/89-22 50-364/89-22 Gentlemen:

7his letter refers to the violation cited in the subject inspection reports which state:

"During the Nuclear Regulatory Commission (NRC) inspection conducted on September 11 - October 10, 1989, a violation of NRC requirements was identified.

The violation involved unapproved overtime hours for licensed operators. In accordance with the ' General Statement of Policy and Procedure for NRC Enforcement Actions,' 10 CrR Fart 2, Appendix C (1989), 53 red. Reg. 40019 (October 13, 1988), the violation is cited belows t Technical Specification 6.2.2.f. requires that adequate operations shift coverage be maintained without routine heavy use of overtime; individuals are not allowed to work more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> during any seven consecutive day period; during extended shutdown periods, the use of overtime should be considered on an individual basis and not for the entire staff; and

- any deviation from these requirements shall be reviewed and approved by the General Manager - Nuclear Plant, his designee (Emergency Director) or higher authority.

Contrary to the above during the Unit 2 refueling outage, which occurred between March and May 1989, there were numerous instances where operators were required to routinely work 84 hours9.722222e-4 days <br />0.0233 hours <br />1.388889e-4 weeks <br />3.1962e-5 months <br /> during a seven consecutive day period. Also at least two ROs and one SRO were allowed to work during their off-days even though their off-days followed a work period of seven consecutive 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> days. These operators did not receive prior i approval on the individual basis by the General Manager - Nuclear Plant, l his designee (Emergency Director) or higher authority.

This is a Severity Level IV violation (Supplement I)."

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J, U. S. Nuclear Regulatory Commission ,

. Decemoer 7, 1989 Page 2 Adadssion or Denial ,

t the above violation occurred as described in the subject reports.

Reason for Violation this violation was caused by personnel error.

Corrective Action Taken and Results Achieved No immediate corrective action was lequired. The violation occurred during the Unit 2 refueling outage. The advert.e condition no longer existed when the violation was received. .'

Corrective Steps to Avoid Purther Violations To ensure that personnel do not deviate from Technical Specification overtime limits without proper management approval, the following actions have been taken:

1) The General Manager - Nuclear Plant has retrained all managers on the intent of the overtime procedures. '

2) Managers have retrained their supervisors, down to and including first line supervisors, on overtime procedures.

l To ensure that a control mechanism exists to verify adherence to specified overtime limits, the following additional actions have been completed:

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1) A system has been established to provide an independent check of all time sheets each pay period to check for adherence to overtime limits.

Errors noted are to be reported directly to management.

2) A system has been established to provide a report to management each pay period listing Operations and Health Physics personnel who worked a predetermined number of overtime hours per week.

Date of Pull Compliance ,

November 28, 1989 Comments Alabama Power Company recognises that extended periods of excessive overtime can lead to fatigue, a decline in norale and degraded performance. The

, ..o I

. . U. S. Nuclear Regulatory Comission

. December 7, 1989 Page 3 refueling outages at rarley thiclear Plant typically last only forty to sixty days which minimizes the cumulative effects of overtime, rurther, having '

used the present overtime schedule for refueling outages over the last ten years, rarley Nuclear Plant's subjective experience base does not suggest a tendency toward increased operator errors. Alabama Power Company will approve overtime use in accordance with Technical Specification requirements.

_ Affirmation I affirm that this response is true and complete to the beat of my knowledge, information, and belief. The information contained in this letter is not considered to be of a proprietary nature.

Respectfully submitted, l

ALABAMA POWER COMPANY h.h . / Y W. G. Hairston, III WGHiemb-5.4 cc Mr. S. D. Ebneter Mr. E. A. Reeves Mr. G. r. Maxwell i,

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