IR 05000254/1987021
| ML20236T171 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 11/16/1987 |
| From: | Creed J, Mallett B, Pirtle G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20236T156 | List: |
| References | |
| 50-254-87-21, 50-265-87-21, NUDOCS 8712010056 | |
| Download: ML20236T171 (6) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION III
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' Report No. 50-254/87021(DRSS); 50-265/87021(DRSS)
Docket No. 50-254; 50-265 License No. DPR-29; DPR-30 Licensee: Commonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Facility Name: Quad Cities Nuclear Generating Station, Units 1 and 2 Inspection At:
NRC Region III Office Inspection Conducted: August 31 through October 29, 1987 Date of Previous Physical Security Inspection: June 23-26, 1987
. Type of Inspection:
Special Allegation Review Inspector:
A.$. hey"_
gi (iq,l B1 G. L. Pirtle Date
' Physical Security Inspector Reviewed By:
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h//G//7 J/.)R.-Creed, Chief Da~te SYfeguards Section Approved By:
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S. Mallett, Ph.D., Chief Date clear Materials Safety and Safeguards Branch Inspection Summary Inspection on August 31 through October 29, 1987 (Reports No. 50-254/87021(DRSS)
No. 50-265/87021(DRSS))
Areas Inspected:
Included a review of an allegation that security force members were required to work excessive overtime hours. One supervisor
, allegedly was required to work 110 hours0.00127 days <br />0.0306 hours <br />1.818783e-4 weeks <br />4.1855e-5 months <br /> in a seven day period, and another security officer was allegedly required to work 28 hours3.240741e-4 days <br />0.00778 hours <br />4.62963e-5 weeks <br />1.0654e-5 months <br /> within a 31 hour3.587963e-4 days <br />0.00861 hours <br />5.125661e-5 weeks <br />1.17955e-5 months <br /> period.
On August 12, 1987, disciplinary action involving a security officer was allegedly caused by fatigue because of excessive overtime hours. The inspection was conducted by one NRC inspector.
Results:
No violations of NRC requirements were noted. The specific allegations were not substantiated. However, the licensee security management agreed to closer monitor security force working hours during nonemergency conditions to address our concern pertaining to one security force member being scheduled to work 28 hours3.240741e-4 days <br />0.00778 hours <br />4.62963e-5 weeks <br />1.0654e-5 months <br /> within a 32 hour3.703704e-4 days <br />0.00889 hours <br />5.291005e-5 weeks <br />1.2176e-5 months <br /> period.
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8712010056 871124 ADOCK 05000254:
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l-l DETAILS 1.-
Persons Contacted.
- P. Laird, Director, Corporate Security, Commonwealth Edison Company (CECO)
- G. Toleski, Nuclear Security Administrator (CECO)
- K. Leach, Station Security Administrator (CECO)
S. Battern, Contract Security Force Manager, Burns International Security Services, Inc. (BISSI)
R. Higgins, Senior Resident Inspector, USNRC Region III A. Morrongiello, Resident Inspector, USNRC Region III The asterisk (*) denotes those present during the Exit Interview conducted on October 29, 1987.
l 2.
Entrance and Exit Meeting (MC 30703):
a.
Or, August 31, 1987, the Station Security Administrator (SSA) was contacted by telephone and advised of the nature of the allegation.
The.SSA was requested to review security force working hours for a soecified period of time, analyze the data, and provide NRC Region III the analysis and time sheets for the security organization for the time period specified (Refer to Section 3.b(2)(a) for details).
i b.
The inspector conducted a telephone exit meeting with the licensee representatives denoted in Section 1 on October 29, 1987. The licensee representatives were advised of the specific allegations and conclusions as addressed in Section 3 of the Report Details.
The inspector also confirmed the commitment pertaining to monitoring security force working hours as addressed in Section 3.b(2)(b) of the Report Details. The licensee representatives present during the telephone exit meeting had no questions or comments pertaining to the allegations or conclusions. They were advised that the allegation conclusions were subject to NRC Region III management review and that the final inspection report would contain the formal perspective of the inspection results.
They were also informed that the inspection report would be placed in the NRC Public Document Room.
3.
Investigation - Allegation Review: The following information, provided in the form of allegations, was reviewed by the inspector as specifically noted below:
a.
Background:
(Closed) Allegation No. RIII-87-A-0113. The NRC Region III office received an allegation on August 13, 1987, that security officers at the Quad Cities Nuclear Plant were required to work excessive overtime hours.
The Station Security Administrator was contacted on August 31, 1987, and requested to provide NRC Region III with time sheets for the security force for the July-August 1987 time period.
He was also requested to provide an analysis of hours worked using the criteria l
of personnel working greater than 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> in a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period; greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in a 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> period; and greater than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />
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in.a seven day period. 'The requested time sheets' and analysis were l
received by NRC Region-III on September-18,.1987. The NRC Region III
' staff. analysis of the data was completed on October 27, 1987, and a telephone exit meeting was conducted on October 29, 1987.
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The: specific allegation, NRC review actions, and conclusions are addressed below:
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.(1)- Allegation:. An anonymous security officer, employed by Burns International' Security Services, Inc. (BISSI) advised NRC Region III on August 13, 1987,'that within a few days prior to August 13, 1987,. a security officer was required.to work a 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> shift, was off for.three hours, and returned to work.for-another 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> shift (28 hours3.240741e-4 days <br />0.00778 hours <br />4.62963e-5 weeks <br />1.0654e-5 months <br />'within a 31 hour3.587963e-4 days <br />0.00861 hours <br />5.125661e-5 weeks <br />1.17955e-5 months <br />' period). The security officer also describe a situation whereby a security force supervisor allegedly worked a regular 40 hour4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> week, plus an additional 70 overtime hours, all within the same week (110 hours0.00127 days <br />0.0306 hours <br />1.818783e-4 weeks <br />4.1855e-5 months <br /> within a seven day period). ' Additionally, the individual that notified NRC Region III stated that one security officer was recently reprimanded for not being attentive to-duties. He implied the inattentiveness was caused by fatigue because of excessive overtime hours. On October 19, 1987, the Senior Resident Inspector advised NRC Region III that he had received some complaints from personnel that security force members were required to work excessive overtime hours.
(2) NRC Review Actions:
(a) The Comission has established no formal regulatory basis pertaining-to working hours for security force members and the licensee's security plan does not address work hours. However, excessive work hours by armed security force. members could constitute a potential safety issue i
because of the affect-fatigue could have on a possible firearms related incident. Section 03.05 of Inspection i
Procedure 81022, ". Security Organization" dated May 5,1984,
provides the following guidelines in relation to scheduled work time for security force members (excluding time for i
shift turnover):
1.
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.
2.
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 /> in any 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period, nor more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in any 48-hour period, nor more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in any seven day period.
3.
A break of at least eight hours should be allowed between work periods.
4.
The use of overtime should be considered on an individual basis and not for the entire staff on a shift.
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a The Station Security Administrator's analysis of security force work hours provided to NRC Region III for the period of June 25 through August 27, 1987, showed the following conclusions in reference to the guidelines:
1.
There were two occasions whereby a security officer worked in excess of 16 consecutive hours. During the week ending July 23, 1987, one person worked 17 hours1.967593e-4 days <br />0.00472 hours <br />2.810847e-5 weeks <br />6.4685e-6 months <br />, 22 minutes consecutively, but the total hours for the seven day work week was 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br /> and 22 I.
minutes. During the week ending August 27, 1987, one f1 person worked 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> and two minutes consecutively,
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but only 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> and two minutes for the seven day work week.
2.
There was only one occasion whereby a person worked
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in excess of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in a seven day period (work week).
That occurred the week ending August 13, 1987, and the a
individual worked 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and 25 minutes during the j
seven day pay period. This also represented the greatest number of hours worked by any security force member within a seven day period (work week) between June 25 and August 27, 1987. This individual's longest consecutive work day consisted of twelve hours.
3.
Overtime was required on an individual basis rather than for an entire shift during the June 25 through August 27, 1987 time period.
4.
There were 11 occasions wheretly security officers worked in excess of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in a 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> period.
(Three for week ending July 16; two for week ending July 30; five for week ending August 13; and one for week ending August 27,1987).
Twenty-eight hours were the maximum number of hours worked within a 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> period.
5.
There was one occasion during the July 30, 1987 work week whereby a security officer received only a four hour break between work periods.
In this case, the officer worked 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> with a four hour break and
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returned for another 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> shift.
The maximum number of hours worked by the individual was 28 hours3.240741e-4 days <br />0.00778 hours <br />4.62963e-5 weeks <br />1.0654e-5 months <br /> in a 32 hour3.703704e-4 days <br />0.00889 hours <br />5.291005e-5 weeks <br />1.2176e-5 months <br /> period.
This was the most significant concern noted during the allegation review.
The inspector conducted a random review of the documents provided by the licensee and did not note any significant differences in the analysis performed by the SSA's staff.
Discussions with the SSA showed that the five occasions where personnel worked greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in a 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> period for the week ending August 13, 1987, were caused
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l due to escort duty requirements to support unplanned work performed on a transformer. Additionally, eight officers that had completed all training requirements and prepared j
to start work during that week were delayed in obtaining registration certificates from the State of Illinois.
l Compensatory measures for mainter,ance and planned security computer outages were cited by the SSA as the reason for the three occasions whereby personnel worked greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in a 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> period for the week ending July 16, j
1987. The other three occasions where personnel worked in excess of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in a 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> period, and where the working hour guidelines were not met, involved isolated incidents.
(b) During interviews with the SSA, he agreed that the working hour guidelines contained in Inspection Procedure 81022 were reasonable and committed to adhere to the guidelines whenever possible for nonemergency situations. He stated that the contract security force manager would be required to notify him if a deviation from the guidelines occurred.
This would enable the SSA to determine in a timely manner if the deviation from the guidelines was an isolated occurrence, poor scheduling, or an indication that additional personnel may be required. This commitment will be monitored during a future inspection (254/87021-01; 265/87021-01).
During followup interviews with the SSA on October 19, 1987, in reference to the senior resident inspector's input, the SSA advised the inspector that no personnel have
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exceeded the working hours identified in the guidelines i
.ince August 27,1987 (latest date of data provided to NRC s
Region III).
He also stated that he had changed manning requirements for two nonsecurity posts to remain within the parameters agreed upon.
(c) The inspector also reviewed the allegation that a security officer was reprimanded because of inattentiveness to duty caused by fatigue because of forced overtime.
Interview results with the contract cecurity force manager showed that an officer was reprimanded for inattentiveness to duty on August 12, 1987. The officer was posted along a sector of the perimeter fence as a compensatory measure and was observed with his back to the perimeter zone.
The sector was also being observed by a close circuit television camera so a violation of the security plan did not occur. The contract security force manager stated that fatigue was not a factor raised by the individual
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during their followup investigation of the incident.
The inspector's review of the time sheets for the week ending August 13, 1987 showed that the security officer had worked only eight hours total in the three days preceding the incident (August 12,1987) and that he did not work the day preceding the incident (August 11,1987). Additionally,
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W the~ individual had worked only five or six hours on August 12, 1987 before being relieved for inattentiveness'
to' duty.
Fatigue because of excessive work hours does not appear to be a factor in the incident.
(3) Conclusions:.The following conclusions were determined as a result of the allegation review:
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l (a) There are' no regulatory requirements addressing excessive work hours for the security force. A review of the licensee's analysis of security force hours worked between June 25 to August 27, 1987, and a random review of the data by the inspector, showed that the guidelines for working hours.centained in Inspection Procedure 81022, dated May 5, 1984, were generally complied with, except for a few occasions where the deviations appeared warranted. The licensee's agreement to closely monitor.and comply with the work hour guidance contained in IP 81022 during nonemergency conditions should assure timely notification to-licensee security management personnel when security force members work excessive hours so' management can analyze the situation and direct actions if warranted.
(b) The specific allegation that a security officer had worked 28 hours3.240741e-4 days <br />0.00778 hours <br />4.62963e-5 weeks <br />1.0654e-5 months <br /> within a 31 hour3.587963e-4 days <br />0.00861 hours <br />5.125661e-5 weeks <br />1.17955e-5 months <br /> period with a three hour break between work shifts was not substantiated.
However, there was at least one occasion whereby a security officer worked 28 hours3.240741e-4 days <br />0.00778 hours <br />4.62963e-5 weeks <br />1.0654e-5 months <br /> within a 32 hour3.703704e-4 days <br />0.00889 hours <br />5.291005e-5 weeks <br />1.2176e-5 months <br /> period with only a four hour break between work shifts. The SSA concluded this resulted from a scheduling error. The commitment pertaining to monitoring work hours will assure timely notification to licensee management for future occurrences of this nature.
Additionally, the allegation that a security force supervisor had worked 110 hours0.00127 days <br />0.0306 hours <br />1.818783e-4 weeks <br />4.1855e-5 months <br /> (40 regular and 70 overtime hours) within the same workweek (seven days) was not substantiated.
(c) Fatigue due to excessive work hours was not a factor in the August 12, 1987 incident involving a security officer being reprimanded for inattention to duty.
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