Information Notice 1991-36, Nuclear Plant Staff Working Hours

Nuclear Plant Staff Working Hours

ML031190507
Person / Time
Site:	Beaver Valley, Millstone, Hatch, Monticello, Calvert Cliffs, Dresden, Davis Besse, Peach Bottom, Browns Ferry, Salem, Oconee, Mcguire, Nine Mile Point, Palisades, Palo Verde, Perry, Indian Point, Fermi, Kewaunee, Catawba, Harris, Wolf Creek, Saint Lucie, Point Beach, Oyster Creek, Watts Bar, Hope Creek, Grand Gulf, Cooper, Sequoyah, Byron, Pilgrim, Arkansas Nuclear, Three Mile Island, Braidwood, Susquehanna, Summer, Prairie Island, Columbia, Seabrook, Brunswick, Surry, Limerick, North Anna, Turkey Point, River Bend, Vermont Yankee, Crystal River, Haddam Neck, Ginna, Diablo Canyon, Callaway, Vogtle, Waterford, Duane Arnold, Farley, Robinson, Clinton, South Texas, San Onofre, Cook, Comanche Peak, Yankee Rowe, Maine Yankee, Quad Cities, Humboldt Bay, La Crosse, Big Rock Point, Rancho Seco, Zion, Midland, Bellefonte, Fort Calhoun, FitzPatrick, McGuire, LaSalle, Fort Saint Vrain, Shoreham, Satsop, Trojan, Atlantic Nuclear Power Plant
Issue date:	06/10/1991
From:	Rossi C Office of Nuclear Reactor Regulation
To:
References
IN-91-036, NUDOCS 9106040339
Download: ML031190507 (7)

- -.

UNITED STATES

NUCLEAR REGULATORY COMMISSION

OFFICE OF NUCLEAR REACTOR REGULATION

WASHINGTON, D.C. 20555 June 10, 1991 NRC INFORMATION NOTICE NO. 91-36: NUCLEAR PLANT STAFF WORKING HOURS

Addressees

- All holders of operating licenses or construction permits for nuclear power

reactors.

Purpose

This information notice is intended to alert addressees of potential problems

resulting from inadequate controls to prevent excessive plant staff working

hours. It is expected that recipients will review the information for appli- cability to their facilities and consider actions, as appropriate, to avoid

similar problems. However, suggestions contained in this information notice do

not constitute NRC requirements; therefore, no specific action or written

response is required.

Description of Circumstances

On October 4, 1990, Braidwood Station, Unit 1 lost approximately 620 gallons of

water from the reactor coolant system (RCS) while the reactor was in cold

shutdown. The Braidwood technical staff was conducting two residual heat

removal (RHR) system surveillances concurrently. Before fully closing an RHR

system vent valve in accordance with one surveillance procedure, the staff

opened an RHR system isolation valve as specified in the other surveillance

procedure. RCS coolant at 360 psig and 180 0 F exited the vent valve, ruptured a

tygon tube line, and sprayed two engineers and the equipment attendant who were

in the vicinity of the vent valve. An NRC augmented inspection team (AIT)

conducted an onsite review of this event. The AIT reported that the fatigue

from excessive use of overtime by the technical staff was a main contribu- tor to this event.

In an August 1990 NRC Diagnostic Evaluation Team (DET) report, the NRC staff

documented high amounts of overtime for personnel at the Zion Station. Indi- viduals in the operations department regularly exceeded the working hour

guidelines contained in Generic Letter 82-12, Nuclear Power Plant Staff

Working Hours," and in Zion's administrative procedures. In November 1990, the

NRC performed an audit and identified numerous additional deviations from

Zion's administrative procedure for approving, tracking, and reporting overtime.

These deviations occurred in 1989 and 1990.

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If! 91-36 June 10, 1991 Although the audit team could not connect a specific operating event or human

error to fatigue caused by excessive overtime, the amount of overtime worked

caused the NRC concern regarding the adequacy of the licensee's staffing.

Generic Letter 82-12 states that controls established should ensure that, to

the extent practical, personnel are not assigned to shift duties while in a

fatigued condition that could significantly reduce their mental alertness or

their decisionmaking ability. The licensee should employ enough plant opera- ting personnel to maintain adequate shift coverage without routine heavy use of

overtime. The objective is to have operating personnel work a nominal 40-hour

week while the unit is operating.

During the 1989 refueling outage at the San Onofre Nuclear Generating Station, Unit 2, the Southern California Edison Company (the licensee) had an outage

shift schedule policy which required San Onofre Unit 3 operating personnel to

work the same shift schedule as Unit 2. San Onofre Unit 3 was operating in

Mode 1 during this time. Similarly, from March through May 1989 at the Alabama

Power Company's Joseph M. Farley Nuclear Plant, the licensee established an

outage shift schedule for both Unit I and Unit 2 even though only one of the

two units was in an outage. In these cases, plant personnel for an operating

unit were placed on a site outage schedule, a practice that is inconsistent

with the intent of the THI Action Plan, NUREG-0737, Item I.A.1.3, and Generic

Letter 82-12 (letter from S. A. Yarga, NRC, to W. G. Hairston III, Alabama

Power Company, dated May 24, 1991, "Operator Work Schedules at the

Joseph 1M.-Farley Nuc-lear-Plant, Units-1-and 2. _

On November 5, 1990, at the Sequoyah Nuclear Plant, an NRC inspection team

reviewed the records of hours worked for the Operations section for the week of

October 8, 1990. The inspection team found 23 instances of inadequate documen- tation for exceeding overtime limits and 5 instances of overtime authorization

prepared after the fact.

In January 1991 at the Callaway Plant, Unit 1, NRC inspectors reviewed

"time on site' for selected contract personnel for the previous refueling

outage. Two of the contract personnel worked on safety-related systems and

exceeded overtime limits without receiving individual authorizations. However, the licensee had issued a single authorization to cover all of that contrac- tor's personnel engaged in safety-related work. To be consistent with Generic

Letter 83-14, "Definition of 'Key Maintenance Personnel' (Clarification of

Generic Letter 82-12),' Callaway has decided to expand the procedural control

of staff working hours to include engineers when they are 'directing"

safety-related work.

Discussion of Safety Significance:

The safety of nuclear power plant operations and the assurance of general

public health and safety depend on personnel performing their jobs at adequate

levels. Research on extended working hours indicates that the performance of

individuals will degrade without adequate rest after long periods of work.

Fatigue can degrade an operator's ability to rapidly process complex informa- tion such as that presented by off normal plant conditions. In addition, fatigue may Jeopardize the ability to respond in a timely fashion. Further- more, performance errors are more likely to occur as a result of lapses in

IN 91-36 June 10, 1991 short-term memory. Because-individuals performing safety-related duties may be

required to respond quickly to a plant emergency, it is important for plant

management to carefully exercise control over overtime practices in order to

ensure that plant personnel perform adequately.

Related Generic Communications:

1. NRC Generic Letter 82-12, "Nuclear Power Plant Staff Working Hours,"

June 15, 1982.

2. NRC Generic Letter 82-16, ."NUREG-0737 Technical Specifications,"

September 20, 1982.

3. NRC Generic Letter'83-02, .NUREG-0737 Technical Specifications,"

January 10, 1983.

4. NRC Generic Letter 83-14, "Definition of-'Key Maintenance Personnel'

(Clarification of Generic Letter 82-12),, March 7, 1983.

5. NUREG-0737, NTMI Action Plan," November 1980.

This information notice requires no specific action or written response. If

you have any questions about the information in this notice, please contact one

of the technical contacts listed below or the appropriate NRR project manager.

Charles E. Rossi, Director

Division of Operational Events Assessment

Office of Nuclear Reactor Regulation

Technical Contacts: David Desaulniers, NRR

(301) 492-1043 Jesse Arildsen, NRR

(301) 492-1026 Attachment: List of Recently Issued NRC Information Notices

-i

Attachment I

is 91.36

3rne to. 1991 Page 1 of I

LIST OFRECENTLY ISSUED

lRC INF0R1ATION NOTICES

Information Data of

Netice No. Subject Issuance Issued to

91-35 Labeling Reqfrements for 06/07/91 All U.S. Nuclear Regulatory

Transporting Malti-41zard Comeisais (NRC)licensees.

Radioactive xaterials

91-34 Potential Problem to 06/013/91 All holders of O.z or CPs

Identifyir4 Ceases of for neclear power reactors.

Emargency Diesel Generator

Italfunctions

91-33 Reactor Safety Informnation OS/31t91 All holders of OLs or CPa

for Statest uring Exercises for nuclear pomr reactors.

and Emergencies

91-32 Possible Flaws In Certain DS/15/91 All holders of OLs or CPs

Piping System Fabricated .for nuclear power seactors.

by Associated Piping and

Engineering

91-31 Nonconforming Magnaf lx OS/09/91 All holders of O.e Or Cps

magnetic Particle 114m) for nuclear powr reactors.

Prepared Soth

91-30 Inadequate Calibration of 04/23/91 All fuel cycle licensees and

Thermluminescent Sosi- other licensees routinely

nmters Utilized to MNitor handling uashielded uraniue

Extremity DOe at Uranium ateria Is.

Processing snd Fabrication

Facilities

M4.21. Recognitioe of American 04/1O/91 All holders of Me or CPs

Supe. 2 Society of mechanical ngis. for macleer poWer reactors

neers Accreditation Pro- and all recipients of

gram for 1 Sttep Holders XURES-0040 **iceas, Con- tractor and Vendor Inspection

Stetue Report, (ihite Book).

EL

• Operating License

CP* Construction Permit

UNITED STATES

NUCLEAR REGULATORY COMMISSION IP`061A05 b FEES PAIDI

WASHINGTON. D.C. 20555 USrINSI c

OFFICIAL BUSINESS

PENALTY FOR PRIVATE USE. $30

i

IN 91-36 June 10, 1991 short-term memory. Because individuals performing safety-related duties may be

required to respond quickly to a plant emergency, it is important for plant

management to carefully exercise control over overtime practices in order to

ensure that plant personnel perform adequately.

Related Generic Communications:

1. NRC Generic Letter 82-12, "Nuclear Power Plant Staff Working Hours,"

June 15, 1982.

2. NRC Generic Letter 82-16, "NUREG-0737 Technical Specifications,"

September 20, 1982.

3. NRC Generic Letter 83-02, 'NUREG-0737 Technical Specifications,"

January 10, 1983.

4. NRC Generic Letter 83-14, "Definition of 'Key Maintenance Personnel'

(Clarification of Generic Letter 82-12),' March 7, 1983.

5. NUREG-0737, "TMI Action Plan," November 1980.

This information notice requires no specific action or written response. If

you have any questions about the information in this notice, please contact one

of the technical contacts listed below or the appropriate NRR project manager.

Odginal Signed by

Charles E.Rossi

Charles E. Rossi, Director

Division of Operational Events Assessment

Office of Nuclear Reactor Regulation

Technical Contacts: David Desaulniers, NRR

(301) 492-1043 Jesse Arildsen, NRR

(301) 492-1026 Attachment: List of Recently Issued NRC Information Notices

• SEE PREVIOUS CONCURRENCES

DltJEACi~R-S *C/OGCB:DOEA:NRR*RPB:ADM *D/DLPQ:NRR *DD/DLPQ:NRR

C CHEerlinger TechEd JRoe CThomas

05/q-191 K 05/28/91 05/21/91 05/21/91 05/24/91

• OGCB:DOEA:NRR*LHFB:DLPQ:NRR *LHFB:DLPQ:NRR*LHFB:DLPQ:NRR *C/LHFB:DLPQ:NRR

CVHodge DDesaulniers JArildsen WSwenson JWermiel

05/22/91 05/23/91 05/23/91 05/24/91 05/24/91 Document Name: IN 91-36

...

IN 91-XX

May xx, 1991 required to respond quickly to a plant emergency, plant management is 40ecto_

to carefully exercise its control over suctovertime practices in order to

ensure that plant personnel perform adequately.

Related Generic Communications:

1. NRC Generic Letter 82-12, "Nuclear Power Plant Staff Working Hours,"

June 15, 1982.

2. NRC Generic Letter 82-16, "NUREG-0737 Technical Specifications,"

September 20, 1982.

3. NRC Generic Letter 83-02, "NUREG-0737 Technical Specifications,"

January 10, 1983.

4. NRC Generic Letter 83-14, "Definition of 'Key Maintenance Personnel'

(Clarification of Generic Letter 82-12)," March 7, 1983.

5. NUREG-0737, "TMI Action Plan," November 1980.

This information notice requires no specific action or written response. If

you have any questions about the information in this notice, please contact one

of the technical contacts listed below or the appropriate NRR project manager.

Charles E. Rossi, Director

Division of Operational Events Assessment

Office of Nuclear Reactor Regulation

Technical Contacts: David Desaulniers, NRR

(301) 492-1043 Jesse Arildsen, NRR

(301) 492-1026 Attachment: List of Recently Issued NRC Information Notices

Document Name: X' TICE - ARILDSEN, HODGE

• SEE PREVIOUS CONC CD

D/DOE'A:NRR C/OGCB:DOEA:NRR*RPB:ADM D P DDZE

CERos5,S CHBerlinger TechEd J o S

05/ /91 05,i9/91 05/21/91 05f J

OGCB: :DOEA:NRR LHFB:DLPQ:N & LHFB:DLPQ:NRR C/L PQ:NRR

CVHo.Ige vf DDesauln erf JArildsen,~V* JWe miel

054i ./91 05W/91 05/t2/91 1 05/4ce 05/2491

- Cr...

Charles E. Rossi, Director

Division of Operational Events Assessment

Office of Nuclear Reactor Regulation

Technical Contacts: David Desaulniers, NRR

(301) 492-1043 Jesse Arildsen, NRR

(301) 492-1026 Attachment: List of Recently Issued NRC Information Notices

Document Name: INFO NOTICE - ARILDSEN, HODGE

D/DOEA:NRR C/OGCB:DOEA:NRR RPB:ADM D/DLPQ:NRR DD/DLPQ:NRR

CERossi CHBerlinger TechEd JWar9T JRoe CThomas

05/ /91 05/ /91 05/21/91 05/ /91 05/ /91 OGCB:DOEA:NRR LHFB:DLPQ:NRR LHFB:DLPQ:NRR LHFB:DLPQ:NRR C/LHFB:DLPQ:NRR

CVHodge DDesaulniers JArildsen WSwenson JWermiel

05/ /91 05/ /91 05/ /91 05/ /91 05/ /91