IR 05000237/1988020
| ML17202G567 | |
| Person / Time | |
|---|---|
| Site: | Dresden, Byron, Braidwood, Quad Cities, Zion, LaSalle, 05000000 |
| Issue date: | 08/04/1989 |
| From: | Shafer W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17202G566 | List: |
| References | |
| 50-237-88-20, 50-249-88-21, 50-254-88-22, 50-265-88-22, 50-295-88-17, 50-304-88-17, 50-373-88-23, 50-374-88-22, 50-454-88-15, 50-455-88-14, 50-456-88-24, 50-457-88-24, GL-82-02, GL-82-12, GL-82-2, NUDOCS 8908140261 | |
| Download: ML17202G567 (6) | |
Text
U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Reper~ Nas. 50-456/88024(DRP); 50-457/88024(DRP)
50-4b4/88015(DRP); 50-455/88014(DRP)
50-~3~/88020(DRP); 50-249/8802l(DRP)
50-373/88023(DRP); 50-374/88022(DRP)
50-254/88022(DRP); 50-265/88022(DRP)
50-2Y5/88017(DRP); 50-304/88017(DRP)
Docket Nos. 50-456; 50-457 50-454; 50-455 50-i:'.37; 50-249 50-373; 50-374 0(1-254; 50-265 50-295; 50-304 License Nos. NPF-72; NPF-77 NPF-37; NPF-66 DPR-19; DPR-25 NPF-11; NPF-18 DPR-29; DPR-30 DPR-39; DPR-48 Licensee:
Commonwealth ~dison Comp~ny Post Office Box 767 Chicago, IL 60690 Facility Name:
Br2idwood Nuclear Power Station, Units l and 2 Byron Nuclear Power Station, Units l and 2 Uresden Nuclear Generating Station, Units 2 and 3 LaSalle County Station, Units l and 2 Quad Cities Nuclear Generating Station, Units 1 and 2 Zion Nuclear Power Station, Units 1 and 2 Inspection At:
Region III, Glen Ellyn, Illinois Inspection Conducted:
August 16, 1988 to August 2, 1989 lnspectors:
R. Lerch M. Kunowski LJ o sf,.*~- ~/)
W. D. Shaf~"l._,,~hief Approved B.}":
Reactor Projects Branch Inspection Surrunary
~/4/09 Date Ins~ection from August 16, 1988 to Au~ust 2, 1989 (Relort No /88024(DRP); 50-457/S8o24(DRP)0-454/88015(DRP~; 50-455/88014(DRP);
50-237/88020(0RP); so-249/aao21(DRP) so-373/8ao23(DRP); 5o-374/aao22(0RP);
5o-254/88022(DRP); 5o-265/88022(DRP) 5o-295/88017(DRP); 50-304/88017(DRP)
Areas Inspected:
Special unannounced inspection by region-based inspectors of procedures and data regarding control of overtime in accordance with the NRC Policy Statement "Nuc~ear Power Plant Staff Working Hours" and an allegatio Results:
No violations or deviations were identified; however, several concerns were forwarded to the licensee for respons C -1 * 1 R90804 890814 1~0
~5000237 PDR ADOC~
PNU Q
- DETAILS Persons Contacted -
Commonwealth Edison Company (CECo)
- John F. Gudac, Corporate Maintenance Superintendent
- Frank Rescek, Assistant Radiation Protection Director
- Neil P. Smith, BWR Licensing Supervisor
~Gerald L. DeYoung, BWR Licensing Engineer
+*Richard Flessner, PWR Operations
+ Thomas Kovach, Nuclear Licensing Manager.
+Steven hunsader, Nuclear Licensing Administrator
+ Charles Sargent, Administrative Engineer
- Denotes those attending the working meeting conducted on August 19, 1988, and at other times throughout the inspection perio +Denotes those contacted by telephone call on August 2, 198.
Details This inspection was conducted to determine the overtime practices at each of the lite~see 1 s nuclear sites and whether they meet the "Policy on Factors Causing Fatigue of Operating Personnel at Nuclear Reactors" which was issued in Generic Letter No. 82-12 on June 15, 198 The inspectors reviewed the Technical Specifications (TS), procedures and lice11see correspondence with the NRC regarding overtime limit Overtime records covering four two-week pay periods at Braidwood, Dresden anci LaSalle were reviewed to evaluate the amount of overtime usag Byron and Braidwood are required by Technical Spec1 icat1on
.2.2.e to develop and implement administrative procedures to limit the working hours of unit staff, such as licensed senior operators, licensed operators, health physics personnel, equipment operators, and key maintenance personnel; who perform safety-related function The amount of overtime worked by unit staff members performing safety-related functions shall be limited in accordance with the NRC Policy Statement on working hours as contained in Generic Letter 82-1 The inspectors determined that Byron and Braidwood have developed administrative procedures to satisfy the technical specification:
The procedures in place at the time of the inspection were Byron procedure BAP 100-7, (Revision 3, October 15, 1986), "Overtime -
Guidelines for Personnel That Perform Safety Related Functions,"
and Braidwood procedure BwAP 100-7, (Revision 0, July 26, 1985),
"Overtime Guidelines for Personnel That Perform Safety Related Functions.
Discussions with licensee representatives and a review of these procedures indi~ate that the licensee applies the procedure
only to individuals who perform both safety-related work and who compose the TS required minimum shift complemeri During the time period inspected for Braidwood (56 days) the amount of overtime worked in days of 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br />,by department, was as follows:
Operations - 316 instances where a 16 *hour day was worked Maintenance - 174 instances where a 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> day was worked Radiological - 150 instances where a 16 _hour day was worked lhe total number of individuals working 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> days was not determine As indicated in the data where individuals worked consecutive days with a 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> shift per day, it appeared* that operations personnel exceeded the L4 in 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> limit on six occasions. Maintenance personnel exceeded the 24 in 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> limit on three occasions. Radiological/Chemistry personnel exceeded the L4 in 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> limit on 14 occasions, once with four consecutive 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> days and twice with three consecutive 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> day The inspectors determined that all licensed operators met the policy but could not determine whether the other individuals were
µerforming safety-related work as part of the shift complement to whom the GL 82-12 guidelines are applied or whether appropriate management approval was granted for this overtim LaSalle:
LaSalle is required by Technical Specification 6.1.C.7 to develop and implement administrative procedures to limit the working hours of unit staff, such as, senior reactor operators, reactor operators, health physicists, auxiliary operators, and key maintenance personnel, who perform safety-related function The TS also states that adequate shift coverage shall be maintained without heavy use of overtime, but if unforeseen problems occur that require the us~ of substantial amounts of overtime, overtime shall be used following specified guideline The guidelines, specified in the TS, match the NRC policy statemen Deviations from the guidelines shall be authorized by the Production or Services Superintendent or higher level of managemen The authorization shall be in accordance with procedures and the basis for the deviation shall be documente The procedures are also required to include controls such that individual overtime shall be reviewed monthly to assure that excessive hours have not been assigne Routine deviations from the hour guidelines in the TS are not allowe The inspectors determined that LaSalle has developed administrative procedure LAP-100-17 (Revision 5, January 25, 1988), "Overtime Guidelines for Personnel that Perform Safety Related Functions,"
to satisfy the T Discussions with licensee representatives, a review of the procedure, and a letter from the licensee to the NRC dated May 4, 1982, indicate that the licensee's applies the procedures only to individuals who preform both safety-related work and who compose the TS required minimum shift complemen In the letter on May 4, 1982, the licensee also states that they interpret the TS to apply only during operational conditions 1, 2, and This interpretation is based on a statement in the March 1981 LaSalle SER that overtime restrictions apply except for "extended periods of shutdown for refueling, major maintenance, or major plant modifications."
Vuring the time period inspected for LaSalle (56 days), the amount of overtime worked in days of 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> or longer by department, was noted as follows:
Operations - 196 instances where a 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> day was worked Maintenance - 441 instances where a 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> day was worked Radiological - 491 instances where a 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> day was worked The total number of individuals working ~6 hour days w~s not determine As indicated in the data where individuals worked consecutive days with a 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> shift pe:r day, it appeared that operations personnel exceeded the 24 in 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> guideline on four occasions. Maintenance personnel
_
exceeded the 24 in 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> guideline on 17 occasions. Radiation-Chemistry personnel exceeded th~ 24 in 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> guideline on 20 occasion The inspectors determined that licensed operators met the policy but could not determine whether the oth~r individual~ were performing safety-related work as part of the shift to whom the GL s2~12 guidelines are applied or whether appropriate management approval was granted for this overtim Dresden:
Dresden is required by Technical Specification 6.2.A. 14 to prepare, approve, and adhere to detailed written procedures on working hcurs of the Shift Engineer, Station Control Room Engineer, Shift Foreman, and Nuclear Station Operator job classifications such that the heavy use of overtime is not routinely required (a TS with wording nearly identical to the Dresden TS are in effect for Quad Citjes and-Zion).
Dresden has developed admi11istrative. procedure OAP 7-1, "Operations
!Jepartment Urganization," to satisfy the T To strengthen admin-istrative control~, Dresden has also developed procedure DAP_7-21, (Revision 0, October 28, 1987), "Station Policy on Reactor Operator and Senior Reactor Operator Manning Levels and Overtime."
Dresden TS and procedures did not control the overtime of non-licensed operators, maintenance or rad chem personnel, however, in response to inspection report 237/8809(DRSS) a letter addressed to A. B. Davis dated July 5, 1988, the licensee committed to applying guidelines to a 11duty" radiation protection technician and a chemistry technician assigned to the safety-related dutie The licensee also provided the background of _submittals made to satisfy NUREG-0737 Post-TMI action item I.Al.3. l
"Limit Overtime".
In attachment 1 of the response the licensee provided the following summary from a letter E. D. Swertz, CECo Nuclear Licensing Administrator to D. G. Eisenhut, Director, NRC Division of Licensing -
.dated June 4, 1982:
11We are in substantial compliance with both the NUREG-0737 and Generic Letter 82-02 requirement The subject overtime limitation for the Shift Engineer, Shift Foreman, Station Control Room Engineer and the Nuclear Station Operator is administratively covered by procedur For theadditional job classifications identified in the NUREG and Generic Letter, Dresden maintains a sufficient number of personnel such that overtime, even for extended outages, is not routinely scheduled to extend beyond a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> shift. Per the November lO, 1981 letter from T. A. Ippolito to L. DelGeorge, the NRC Staff has found that our previous 4 *
correspondence adequately addresses the shift manning overtime limit requirement This item is considered complete."
For the time period inspected for Dresden (56 days}, the amount of overtime worked in days of 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> or longer by department, was noted as follows:
Operations - 115 instances where a 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> day was worked Maintenance - 124 instances where a 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> day was worked Radiological - 210 instances where a 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> day was worked The total number of individuals working 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> days was not determine As indicated in the data where individuals worked consecutive days with a 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> shift per day, it appeared that the operations department exceeded the 24 in 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> guideline seven times, with three individ~als working three consecutive 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> days and one working four consecutive 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> day Maintenance employees exceeded the 24 in 48 limit 15 times, with two individuals working four consecutive 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> days and five ir.cividuals working three consecutive 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> day Radiation-Chemistry employees exceeded the 24 in 48 limit 40 times and the 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in 7 days lin1it on three occasions when individuals worked five consecu-tive 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> day Individuals also worked four consecutive 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> days on 12 occasions and three consecutive 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> days on six occasion The inspectors determined that licensed operators met the policy but could not determine whether the other individuals were performing safety-related work as part of the TS minimum shift complement to whom the GL 82-12 guidelines are applied, or whether appropriate management approval was granted for this overtim Quad Cities:
Quad Cities has a Technical Specification (6.l.A.14} on overtime with the same requirements as the Dresden T Quad Cities has procedure ~AP 300-3, (Revision 10, July 22, 1988}, "Shift Manning," to satisfy the T As with Dresden, the NRC accepted submittals for Quad Cities including exceptions from procedurally controlling overtime hours for the additional job classifications identified in GL 82-12 i.e. health physicists and key maintenance personne Zion:
Zion has a Technical Specification (6. 1. l.M) on overtime with the same requirements as the Dresden's T Zion procedure ZAP-0, (Revision 1, September 11, 1987}, "Conduct of Operations," was imple-mented to satisfy the TS and is also similar to Dresden' As with Dresden, the NRC accepted submittals for Zion including exceptions from procedurally controlling overtime for health physicist and key maintenance personne Allegation (99024)
(Closed) Allegation (RIII-88-A-103), maintenance and operations employees are working a lot of long shifts. This allegation was substantiated in that overtime records indicated that in the two month period some individuals had worked several consecutive 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> day The records
'
did not show that single individuals were consistently working long shifts but that the overtime usage was spread over a number of employee NRC 1s position on use of overtime is destribed in the policy on "Nuclear Power Plant Staff Working Hours 11 which applies only to certain job classifications performing safety-related wor A great majority of worker overtime does not fall under this polic In addition, safety-related overtir.1e work reviewed and approved by station management is permitted by the polic No deviations from the policy were identified; this allegation is considered close.
Conclusion The sites where overtime records were reviewed (Dresden, LaSalle and Llraidwooci) each have different commitments governing overtime which have been approved by the NR The applicable site procedures accurately reflect these con~itment The us~ of overtin~ as indicated by the work records reviewed did not iriclicate any gross failure to meet the overtime guideline The data also did not reveal that overtim~ usage by individuals covered by ~he policy was routine or heavy although a few instances of heavy overtime (three or more consecutive 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> days) were identifie The inspectors determined that none were licensed operators working without appropriate approva In some instances where overtime use was heavy, it was not possible to determine if the overtime involved safety-related work requiring approval by managemen Overall, there was significant overtime usage spread over a large population of employees. Although no deviations from the overtime policy were identified, the following ccncerns were raised: Some sites only apply the overtime guidelines to the TS minimum shift crew composition. This limitation does not appear justified as safety-related work is performed by personnel other than this cre Overtime policies are not being uniformly applied at all site For example, at Dresden the overtime policy is applied to the Radiation Protection and Chemistry Technician positions. There is no indication that the overtime policy is applied to this same position,at the other five site Where the licensee committed to adequate staffing levels to meet the policy, it is not apparent from procedures or the time records provided that the licensee can effectively ensure that the overtime policy is being me The LaSalle Station appears to apply the overtime policy only during plant modes 1,
~' ~nd It is not clear that the overtime policy is implemented during refueling or major outage These concerns were discussed by telephone with the licensee on August 2, -
198 During the discuision, the licensee informed Region II1 that CECo was just completing an internal review on the same matter and would respond to the above issues in writin