ML18067A546

LER 97-006-00:on 970412,overtime Limits Were Exceeded for Radiation Protection Technicians.Caused by Inadequate Design,Review & Proper Verifications of Overtime Work Schedule.Communicate Overtime Limitation Responsibilities

ML18067A546
Person / Time
Site:	Palisades
Issue date:	05/12/1997
From:	Kozup C CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:
Shared Package
ML18067A545	List: ML18067A544 ML18067A546
References
LER-97-006, LER-97-6, NUDOCS 9705210029
Download: ML18067A546 (6)

Text

NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB NO. 3150-0104

,(4195) EXPIRES 4130/98 ESnllATED llJUlEN PER RESPONSE TO COMPLY wffil "MS MANDATORY INFORMATION COLLECTlON REQUEST: 50.0 HRS. REPORTED LESSONS LEARNED ARE INCORPORATED LICENSEE EVENT REPORT (LER) INTO THE LICENSING PROCESS AND FED BACK TO INDUSTllY. FORWARD COMMENTS REGARDING BURDEN ESTIMATE TO THE INFORMATION AND RECORDS MANAGEMENT

-- ~- "' BRNICH (T-8 F33). U.S. NUCLEAR REGULATORY COMMlsSION, WASHINGTON, DC 20S5S-0001, AND TO "THE PAPERWORK REDUCTION PROJECT (31~104; OFFICE OF (See re11erse for required number of. digits/characters for each block) MANAGEMENT AND BUDGET, WASHINGTON, DC 20503.

FACILITY"NAME.(1) CONSUMERS POWER COMPANY I DOCKET NUMBER (2) Page (3)

PALiSADES NUCLEAR PLANT 05000255 1of6.

TITLE(4) LICENSEE EVENT REPORT 97-006- OVERTIME LIMITS EXCEEDED FOR RADIATION PROTECTION TECHNICIANS . .

.. EVENT DATE (5) LER ~UMBER (6) REPORT DATE (7) OTHER FACILITIES INVOLVED (8)

MONTH DAY YEAR YEAR I SEQUENTIAL

. NUMBER*

REVISION NUMBER MONTH DAY YEAR FACILITY NAME DOCKET NUMBER 05000 *'*

FACILITY NAME . DOCKET NUMBER*

04 12 97 97 - 006 - 00 05 12 97 . 05000

• OPERATING . THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR§:-(Check one or more) (11) ..

~ODE (9)

• N .. 20.2201(b) 20.2203(a)(2)(v) x 50.73(a)(2)(i) 50. 73(a)(2)(iii)

POWER 20.2203(a)(1 l 20.2203(a)(3)(i) 50, 73(a)(2)(ii) 50:73(a)(2)(x)

LEVEL (10) 99.6 20.2203(a)(2)(i) 20.2203(a)(3)(ii) 50. 73(a)(2)(iii) 73.71 .* *,

. 20.2203(a)(2)(ii) 20.2203(a)(4) . 50.73(a)(2)(iv) OTHER t:;;'i!:;i:<*:. "' ! r;;@ *it..:./'*.*.*..:

20.2203(a)(2)(iii) 20.2203(a)(2l<ivl 50.36(c)(1) 50.36(c)(2)

50. 73(a)(2)(v) 50: 73(a)(2)(vii)

• Specify in Abstract below or in NRC Form 366A

.*. LICENSEE CONTACT FOR.THIS LER (12)

• NAME Cha.rles S. Kozup, Licensing Engineer .. TELEPHONE NUMBER (Include Area Code)

. (616) 764-2000 . . .*

.. .

• COMPLETE. ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT l13)

CAUSE. 'SYSTEM COMPONENT. .MANUFACTURER-* ~

REPORTABLE CAUSE SYSTEM COMPONENT MANUFACTURER REF'c;>RTABLE

• TONPRDS *TO NP.RDS

.. rt

.. SUPPLEMENTAL.REPORT EXPECTED (14) ... MONTH DAY YEAR

.*. I ~~!s COMPLETE EXPE~T~D COM~LETI~~ bA~E . x* 1 NO._ .

EXPECTED SUBMISSION DATE (15)

ABSTRACT (Umit to 1400 spaees, i.e., approximately 15 sin!Jle-spaced:typewritten li~es).(16)

On April_ t.2. :1997, wi.th the plant operating at 9~.6%_ power;. Operations. pers_onnel w~re:dis¢ussirig.

working hours with~ Radiation Safety Technician-and discovered three occasions in 1997when ,.

• the Overtime Limitations.ofAdministrative Procedur~*fOO and Technical Specification 6.2.2.e.2_

were exceeded.*. In each case, Radiation SafetyTechliicianswho worked both days of the.

weekend, worked more.than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in a 48-hour period. Subsequent evaluation discovered a*.

total of seven occurrences in 1996 and 1997. *These seven occurrences were determined to).

repre_sent a significant administrative breakdown of the Overtime Limitation's Policy and therefore reportable'to tt:ie.NRG in accordance with 10 CFR 50.73(a)(2)(i)(B) as a condition prohibited by the.

plant Technical Specjficatiornr . * * .. ~ * . * * * ** ,* * .* .

• The Chemieal & Radiological Services (C&RS) Schedule.t took .immediate action to ensure technicians were not scheduled for more than one weekend or holiday shift iri any two day period.

In addition, the Overtime Limitation responsibilities and expectations were communicated to all site and contractor *supervisors. F:uture actions include: reinforcement of Overtime Limitation Program responsibilities to individuals, super-Visors and contractors; clarification of th~ Administrative Procedure t.00 Overtime Limitation Section; and a monthly audit of individual time sheets .

9705210029 970512 PDR ADOCK 05000255 S PDR

NRC FORM 366a U.S. NUCLEAR REGULATORY COMMISSION 4195 LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION FACILITY NAME m LER NUMBER 16\ PAGE l3l I

DOCKETf2l YEAR SEQUENTIAL REVISION NUMBER .NUMBER 05000255 20F6 PALISADES NWCLEAR PLANT 97 - 006 - 00 TEXT (If more space is required, use additional copies of NRC Form 366A) (17)

EVENT DESCRIPTION On April 12, 1997, with the plant operating at 99.6% power, Operations personnel were. discussing working hours with a Radiation Safety Technician and discovered three separate occasions in

.19~7 when the Overtime Limitations of Administrative Procedure 1.00 and Technical Specification 6.2.2.e.2 were exceeded. All three occasions involved Radiation Safety Technicians *who worked both days of the weekend and exceeded 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in a 48-hour period. S.ubsequent evaluation*

discovered one additional.occurrence in 1997 and t_hree occurrences in 1996.. The specific times worked are shown* in Table 1. These seven occurrences were determined to represent a

• significant administrative breakdown of th~ Overtime °Limitations Policy and therefc;>re reportable to Jhe NRC in accordance with 10 CFR 50. 73(a)(2)(i)(B) as a condition prohibited by the *plant * .. '

Technical Specifications. * * * *

.Radiation Safety Technicians.are con~ider~d part of the plant staff that perform safety-related. ..

functicms. Normally, the week~nds arid C Shift are staffed. with or:ily one tec;hnician. The current Radiation Safety Technician schedule was developed approximately ten _(10) .years ago. The*.

normal weekly schedule was: .* *

' .. *A Shift . . 2300- 0730 **. ~

B Shift 0700-1530 C Shift 1500 - 2330 Weekend/Holiday A/B 2300 - 1100

- ~eekend/Holiday B/C - 1100 -2300

- When this schedule was established, a review was performed to ensure that none of the overtime _

limitations of the Technical Specificatic:>ns would be exceed~d. The review looked at various .

rolling periods of time (i.e., 24, 48 and 168 hours0.00194 days <br />0.0467 hours <br />2.777778e-4 weeks <br />6.3924e-5 months <br />) and all potential technician staffing (i.e., by shift and working. weekends/holidays). Based on the results of that review, it was determined that as long as there was a nine (9) hour rest period between shift assignments, no over:time limits would be exceeded. However, this re.view was flawed in that it did not take i'nto account all 48-hour rolling periods of time, specifica_lly the Friday, weekend, and Monday time frames. The result was a potential schedule that could allow more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of work in two specific 48-hour time frames (Friday 8 shift with both weekend A/B_shifts, both weekend B/C shifts with Monday 8 shift; or a weekend coinciding with a holiday). The C&RS Scheduler position has been filled J>y at least three different people since the original review was performed. None of the subsequent schedulers questioned the validity of the review.

NRC FORM 366a U.S. NUCLEAR REGULATORY COMMISSION 4195 LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION FACILITY NAME '1\ DOCKETl2\ LER NUMBER 6\ PAGE (J\

05000255 YEAR I SEQUENTIAL NUMBER REVISION NUMBER 30F6 PALISADES NUCLEAR PLANT 97 - 006 - 00 TEXT (If m?re space is required, use additional copies of NRC Form 366A) (17)

Each "Nonoutage" Radiation Safety Technician schedule is prepared with four separate technicians each working one of the four weekend shifts. This practice allows every technician to'

• have at least one day off per week dufing nonoutage periods. However, technicians are allowed to trade or give their weekend assignments to other technicians. Only after these* trades occur can the overtime restrictions be exceeded. Radiological Services supervision has no~ been involved in weekend trades by the technicians. Supervision had only been involved with weekday overtime.

and shift changes. Because the Radiological Services supervisors had the same understanding of the overtime restrictions as the technicians, we believe that their review would not have identified this problem. However, we .befieve supervisory oversigh~ of weekend ~rades does provide the .

opportunity to prevent excessive overtime from occurring ..

During the evaluation of this event, several other aspects of this overtime problem were identified.  ;.

. 1. Twelve ( 12) conditi6n reports on exceeding overtime, limitations have _been generated since .

. May 1996. Eight (8) of .these twelve involve the 48-hour time period, with the remaining

• involving the 7-day period. The Administrative Department was. involved in eight (8) of*.

, these condition reports, with five. (5) in the Security area. Therefore, this problem does not appear to be *i~olated to a given time period, nor t~ the C&RS Department. * * *

2. *. Some Palisades, Workers, and m~st contractors do not appear to fully understand the '

overtime _limitations; in particular, the application of the "rolling time period" concept.*

3. Technical Specification 6.2.2.e has a statement requiring, "Controls shall be included in the procedures such that individual overtime shall* be reviewed. monthly by the plan~

• superintendent or his designee to ensure that excessive hours have not been assigned."

• The only control was a note in Administrative Procedure 1.00 which reads, "Individual .

overtime shall be revi.ewed by the Plant Manager or his designee to assure 'that excessfve hours have not been assigned." However, discussions with Human Resources and Payroll personnel indicate this review was not being performed.

4.

• Administrat.ive Procedure 1.00 does not clearly explain the management expectation for each individual worker to .be responsible for ensuring 'their own overtime limitatio'ns c:1re not excee_ded without prior approval. The procedure includes responsibilities for ensuring that waivers are completed for SE-W, OM&C and EA&P, but does not indicate who should

, complete waivers for contractors. In addition, personnel interviews identified that expectations are not well understood:

Based on the above discussion, there appears to be some significant programmatic problems with .

overtime limitations within the C&RS Department and the Plant.

NRC FORM 366a U.S. NUCLEAR REGULATORY COMMISSION 4195 LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION

' ~- FACILITY NAME 1 DOCKET 2 LERNUMBER 6 PAGE 3 YEAR SEQUENTIAL REVISION NUMBER . NUMBER 05000255 40F6 PALISADES.NUCLEAR PLANT 97 ' - 006 - 00 TEXT (If more space is required, use additionai'copies of NRC Form 366A) (17)

CAUSE OF THE EVENT

• The following c~uses were identified:

1. The C&RS Technician overtime work schedule was inadequately designed arid reviewed, ..

and proper verifications were .not made.

2. There was a lack of a questioning attitude by C&RS personnel: Excessive weekend'

• sc.heduling w~s allowed because of long"'."standing past practices.

3. C&RS supervision chose not to get involved with technician weekend scheduling practices.

This i~ considered a lack of organiz_ation planning.

4. * .Management expecta_tions for personal responsibility on overtime limitations is not

• consistently understood by all personn~L * * *

~ Some plant personri~1: particularlv contractors, do not understand how to interpret the*

overtime -limitation periods: There is confusion between periods of timer as used for time sheets, and rolling periods of time us*ed with overtime *limitations'.* * *

. ~ ..

Together, these causes* point to a root cause ofinconsistent and less than adequate line man.agement ownership of ~he Overtime Limitation Program. This inconsistent ownership is characterized by significant program elements (i.e., Tec!lnical Specificatio.ns Sec~fori 6.2.2.e review requirement) not being carried out, and unawareness of actual program performance_

• deficiencies which lasted for the past few years. Other examples include, lack of timely and effective self"-assessments, no detection of the condition report trend of exceeding overtime restrictions, and ineffective involvement by field supervision.

ANALvs1s*oF EVENT '

For the overtime violations pertaining to this condition report, there are no safety implications.

Potential implications were minimized by providing rest periods of at least nine* an.d twelve hours between the three consecutive shifts that made up the 48-hour period.* However, the programmatic concerns identified could have led to more significant consequences it fatigue had led to errors. being committed.

The first and most effective barrier to prevent overtime violations is for all Palisades personnel and contractors to understand their personal responsibility for ensuring they do not exceed the overtime limitations. They need to understand how to interpret the "rolling time periods." Plant supervision, while not primarily responsible, can provide an effective barri".!r in preven+ing and ..

identifying over ume violations ..

NRC FORM 366a U.S. NUCLEAR REGULATORY COMMISSION 4195 LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION I

• • FACILITY NAME 11 \ DOCKET12\ LER NUMBER 6\ *

• PAGE 13\

YEAR SEQUENTIAL REVISION NUMBER NUMBER 05000255 50F6 PALISADES NUCLEAR PLANT 97 - 006 - 00 TEXT (If more space is required, use additional copies of NRC Form 366A) (17)

CORRECTIVE ACTIONS

• The C&RS Scheduler took immediate corrective.action to ensure that technicians-were not scheduled for more than one weekend or holiday shift in any two day period'. Exceptions are allowed only if the'48-hour time period limit will not be exceeded as verified by the Radiological Services Supervisor. * * * ' **

Other actions p)anned to GOrrect the causes of this event are:

1. Communicate *Overtime Limitation responsibilities and expectations to all site and contractor s*upervisors. Initial communication has been completed, but follqw-up

• reinforcement to ensure individual, supervisor, and contractor understanding of. Overtime Limitation Program responsibilities will be conducted. Administrative PrOCE;!dure 1.00 will '

be revised to clarify the Overtime Umitation Section to aid in personnel understanding of the program, including:

- Clearly identifying individual responsibilities.

- Clarifying, with examples, the concept of"rolling time periods".*.

- Identifying who.pertorms the Technical Specifications Section 6._2:2.e review of individual overtime.

- -Identifying responsibility for C()mpleti.ng. Overtime Waivers for contractors. ,

• 2. Ensure a monthly audit or re~iew of individual time sheets is performed to the requirement_s

,

• of Technical Specification 6.2.2.e. Results will be communicated to the General Manager Plant Operations at least *on a monthly basis. * * -

• f, . * : ,... ..

Page 6of6

. TABLE 1 - OVERTIME LIMITATION VIOLATIONS Occurrence Friday Saturday _Sunday Monday Tuesday Dates '

1996 . .

5/10-5/12 0700-1400<1> 2300-1100 2300-1100*

5/26-5/28 2*300-1100 2300-1100 0800-1530*<2> .

8/24-8/26 1100-2300 1100-2300 0800-1 530*<2 >

1997 1/17-1/19 . 0700-1406<1> 2300:..1100. 2300-1100*

2/21-2/23  ; 0700-1400<1> . 2300-1100 2300-1100* .

3/1-3/3 11op-2300 1*100-2300 .0800-1530*<2>

415-417 1100-2300 1100-2300 0800-1 530*<2> . .

• Shift on which overtime violation occurred * .

(1) Technician sent ~ome early to allow 9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br /> be.tween *shifts (2) Technician came in. late to allow 9 hows between shifts