ML20024H485
| ML20024H485 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 05/24/1991 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20024H481 | List: |
| References | |
| GL-82-12, GL-82-16, NUDOCS 9106040148 | |
| Download: ML20024H485 (4) | |
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DOCUMENTED EVALUATION TO SUPPORT IMPOSITION OF A COMPLIANCE BACKFIT CONCERNING TECHNICAL SPECIFICATION GUIDELINES FOR OVERTIME AT THE JOSEPH M. FARLEY NUCLEAR PLANT,_ UNITS 1 AND 2 1.
INTRODUCTION The amount of overtime worked by operating personnel at the Joseph M. Farley Nuclear Plant (Farley), Units 1 and 2, during extended periods of shutdown has been a concern to the Nuclear Regulatory Commission (NRC) staff. Alabama Power Company's (APC0's) practice on overtime has been that during a single-unit outage, the unit staffs of both the operating unit and shutdown unit are placed on the same overtime schedule.
This schedule typically includes shif t rotation that results in operators working up to 84 hours9.722222e-4 days <br />0.0233 hours <br />1.388889e-4 weeks <br />3.1962e-5 months <br /> in a 7-day period.
The issue of overtime has been the subject of past correspondence and discussions with APC0.
The following discussion addresses, in part, the interactions between APC0 and the NRC on this issue.
A.
NRC Inspection Report No. 50-364/80-27, issued on August 28, 1980, addressed APCO's commitment to limit overtime to no more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in any saven day period and also discussed APCO's difficulty in meeting all of the overtime guidelines.
B.
NRC Inspection Report Nos. 50-348/88-05 and 50-364/88-05 issued on May 18, 1988, reviewed APC0's use of overtime during normal operation and outages.
Although the report noted that outage overtime exceeded Technical Specification guidelines, the repor+. concluded that the structure of approved overtime during outages was acceptable.
C.
NRC Inspection Report Nos. 50-348/89-14 and 50-364/89-14, issued on July 26,1989, included an unresolved item involving excessive work hours for licensed operators.
D.
A management meeting was held with APC0 on July 31, 1989, to discuss the overtine issue which was documented in NRC Inspection Report Nos. 00-348/89-16 and 50-364/89-16, issued on August 17, 1989.
E.
NRC Inspection Report Nos. 50-348/89-22 and 50-364/89-22 issued on November 9, 1989, further discussed the July 31, 1989, management meeting 9106040140 910524 PDR ADOCK 05000340 P
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2-I and issued a Notice of Violation for exceeding lechnical Specification guidelines for overtime without the proper level of management approval, i
i APC0 responded to the_ violation in a letter dated December 7, 1989, detailing the corrective actions to be taken to ensure that personnel do not deviate from Technical Specification overtime guidelines without proper management approval.
4 F.
NRC Inspection Report Nos. 50-348/90-28 and 50-364/90-28 issued on October 16, 1990, addressed the issue of overtime worked by shift supervisors.
G.
NRC Inspection Report Nos. 50-3a8/90-32 and 50-364/90-32, issued on December 20, 1990, determined that overtime worked by the maintenance staff was in acccrdance with the guidelines contained in Generic letter 82 16. "HUREG-0737 Technical Specifications."
H.
NRC Inspection Report Nos. 50-348/91-06 and 50-364/91-06, issued on April 23, 1991, determined that, for the period evaluated, overtime werked in excess of Technical Specification guidelines was properly approved.
However, APC0's plicy of pre-approved, scheduled, outage overtime in excess of Technical Specification guidelines was still under evaluation.
APC0 has routinely scheduled overtime for the unit staffs of both the i
operating unit and the shutdown unit during a single-unit outage (e.g., five, I
six, seven and seven consecutive work days, 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> per day during a five week period). With proper approval, the NRC ackrowledges that overtime is allowed for a unit in an extended shutdown per Farley, Unit 1 and 2, Technical Specifications 6.2.2.f.
However, the NRC does not consider the scheduling of this quantity of overtime prudent because of the cumulative effects of excessive overtime on performance.
The NRC staff recognizes that extended outages such as refueling often necessitate higher levels of overtime usage than other phases of operation.
Accordingly, Farley, Unit I and Unit 2, Technical Specifications 6.2.2.f. as well as NRC guidance contained in such documents as NUREG-0737, " Clarification
-of TMI Action Plan Requirements;" Generic letter 82-12, " Nuclear Power pla c Staff Working Hours;" and Generic Letter 82-16, allow higher limits for acceptable levels of overtime during extended periods of shutdown for refueling, major maintenance or major plant modifications.
However, this guidance was intended to apply only to the shutdown unit and not to the unit which is still operating.
Technical Specifications 6.2.2.f for both Farley, Unit I and Unit 2, state that the objective shall be to have operating personnel work a nominal 40-hour week while the plant is operating. The NRC staff's position is that during single-unit outages, the staff of the operating unit should continue to work a 1
nominal 40-hour week.
11.
EVALUATION As ApC0 has utilized its current practice for scheduling overtime for a signif-icant period of time, and the staff has indicated in the past that the practice appeared to be acceptable (see Inspection Report Nos. 50-348/88-05 and 50-364/88-05), the imposition of a change was evaluated as a potential backfit in accordance with the criteria contained in 10 CFR 50.109.
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i I the staff's review, imposition of the backfit is justified to bring both f arley, Unit 1 and Unit 2, into compliance with their Technical Specifications 1 Appendix A to Operating Licenses Npf-2 and 8, respectively),
in accordance l
with 10 CFR 50.109(a)(4), a backfit analysis is not required.
The following evaluation constitutes the documented evaluation required by 10 CFR $0.109(a)(6):
l A.
Objective of Modification The staff's objective is to bring Farley, Units 1 and 2, int 9 compliance with their licenses.
APC0 should not use overtime guidelines contained within their licenses that are explicitly designated for use during extended periods of shutdown, to schedule the working hours of the unit staff (as defined in Technical Specification 6.2.,2.f) who perform safety-related functions on an operating unit.
B.
Reasons for the Modification APC0 has systematically allowed operating personnel to work as much as 84 hours9.722222e-4 days <br />0.0233 hours <br />1.388889e-4 weeks <br />3.1962e-5 months <br /> in a 7 day period while performing safety-related functions on an i
operating unit.
This work scheduling practice can result in fatigue, I
thereby reducing the ability of operating personnel to maintain the unit in a safe condition.
C.
Basis for invoking the Compliance Exception APC0 has repeatedly placed the unit staff s for both units on an outage schedule when only one unit has been in an outage.
This practice is not consistent with the staff's intent at the time of approval of the farley Technical Specification amendments that incorporated nyertime guidelines.
Specifically, the practice of placing personnel performing safety-related functions on a unit that is not shutdown does not meet the intent of either the farley, Unit 1 or Unit 2, Technical Specification 6.2.2.f.
Technical Specification 6.2.2.f states:
Adequate shift coverage shall be maintained without routine heavy use of overtime.
The objective shall be to have operating personnel work a nominal 40-hour week while the plant is operating.
Therefore, the unit staff working on an operating unit should enntinue to work a nominal 40-hour week (defined as any 7-day period) regardless of whether the other unit is in an extended shutdown.
The bases for the staff's conclusions are as follow:
1.
The requirement in Technical Specification 6.2.2.f fo" administretive procedures to control overtime for unit staff who perform saf ety -
related functions were developed in response t6 a conutitment to implement the NRC's policy on factors causing fatigue of operating personnel as described in Item I.A.1.3 of NUREG-0737.
Tne objectin of the policy, as stated in item I. A.1.3 of NUREG-0737, ws for administrative procedures to be established "...such that use of overtime is avoided, to the extent practicable, for the niant staff who perform safety-related functions...."
, 2.
By letter dated June 6, 1983, APC0 requested changes to Section 6 of the Technical Specifications to bring the their policy on use of overtime into conformance with the NRC's stated policy on overtin,e restrictions.
The staff found that APC0's request was in accordance with the Commission's Policy Statement regarding the use of overtime as promulgated to all licensees in Generic Letter 82-12.
The requested changes were incorporated into Technical Specification 6.2.2.f by Amendment No. 38 to Operating License NPF-2 and Amendment No. 28 to Operating License NPF-8 for f arley, Units 1 and 2. respectively, dated December 30, 1983.
3.
Generic letter 82-12 promulgated a revised version of the policy which appeared in item 1.A.1.3 of NUREG-0737.
The revisions made in response to public comment included the addit <0n of a sentence which explicitly states that "The objective is to have operating personnel work a normal 8-hour day, 40-hour week, while the plant is operating."
(emphasis added). A phrase was also added to clarity that the stated working hour restrictions (e.g., an individual should 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) were applicable
"...during extended periods of shutdown for refueling, major maintenance or major plant modifications...." Through these modifications, the staff communicated the guidance applicable during periods of operation and shutdown.
4 Generic Letter 82-16 transmitted a model technical specification.
This model technical specification also included a statement that "The objective shall be to have operating personnel work a normal 8-hour day, 40-hour week, while the plant is operating." The model technical specification was written
"...to limit the working hours of unit staff who perform safety-related functions..." (emphasis added).
5.
Farley, Units 1 and 2, have unit specific Technical Specifications.
The operating mode of each unit is determined in accordance with its own Technical Specifications and is not determined by the operating mode of the other unit.
Therefore, the shutdown of one unit cannot be used to determine tne applicanle work hour guidelines for the operating unit.
111.
CONCLUSION Based on the above evaluation, the staff finds thot the imposition of a backfit concerning APC0's scheduling of overtime for operating unit personnel is justified as a compliance exception under the W teria contained in 10 CFR 50.109. APC0 is required to modify its work schedules to ensure that the unit staff on on operating unit works a nominal 40-hour week.
Principal Contributors:
D. Desaulniers S. Hoffan Date:
May 24, 1991
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