Text

Partially Deleted Ltr Forwarding Allegation Evaluation Rept RII-97-A-0015 Re Female Visitors Not Being Informed About Monitoring of Embryo/Fetus Prior to Gaining Access to Radiologically Controlled Area
	ML20202E061
Person / Time
Site:	Saint Lucie
Issue date:	04/08/1997
From:	Barr K; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	; AFFILIATION NOT ASSIGNED
Shared Package
ML20202D873	List: ML20202D870; ML20202D926; ML20202D959; ML20202D990; ML20202E039; ML20202E061; ML20202E076;
References
	FOIA-97-484 50-335-97-02, 50-335-97-2, 50-389-97-02, 50-389-97-2, NUDOCS 9802180057
	Download: ML20202E061 (9)
	v • d • e

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[pa atop'% UNITED STATES -

NUCLEAR REGULATORY COMMISSION

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.... April 8, 1997 ,

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d SUBJECT.:-. RII 97 A 0015 FEMALE VISITORS WERE NOT BEING ITE5iED ABOUT T MONITORING OF AN EMBRY0/ FETUS PRIOR TO GAINING ACCESS TO THE RADIOLOGICALLY CONTROU EO AREA (RCA) -

.a 7d -

Qu This refers to our letter dated February 14, 1997, in which we advised you W '

o that we were continuing our review of the concern you expressed regarding female visitors not being informed about monitoring of an embryo / fetus prior to gaining access to the radiologically controlled area (RCA) at th'e St. Lucie NuclearPlant. _

i Our inspection.regarding this matter has been completed and our findings are i

documented in the enclosures to this letter. Female visitors are not required

! by regulation to be informed of potential health risks to an embryo / fetus prior to gaining access to the radiological controlled area (RCA). Your concern was substantiated, however, no violations of regulatory requirements were identified.

This concludes the staff's activities regarding this matter. If you have any questions, you may contact me at 1 800 577 8510 or (404) 331 0335 or by mail at P.O. Box B45, Atlanta, GA. 30301.

Sincerely,

~

Kenneth P. Barr, Chief Plant Support Branch Division of Reactor Safety CetifiedMailNo.ZI38518025 RETURN RECEIPT REQUESTED

Enclosures:

1. Allegation Evaluation Report

2. Report Nos. 50 335/97 02 and 50 389/97-02

~

9802180057 900123 '

TO 484 PDR trdo:matica in this record was dettled in accordance with the Freedom of Information Act, exemphpns 7C F0IA- - Y7- #8 Y

'fs o u r ooS7 '

April 8, 1997

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SUBJECT:

RII 97 A 0015 FEMALE VISITORS WERE NOT B U G INFORMED A HONITORING OF AN EMBRYO / FETUS PRIOR TO GAINING ACCESS TO THE

\ RADI0 LOGICALLY CONTROLLED AREA (RCA) b - !

This referf to our letter dated February 14, 1997, in which we adWiied you x that we were continuing our review of the concern you expressed regarding 4

tu female visitors not being informed about monitoring of an embryoHetus prior -

.Q to gaining access to the-radiologically controlled aree-(RCA) at the St. Lucie

Nuclear Plant.

4 Our inspection regarding this matter has been completed and our findings are i documented in the enclosures to this letter. Fennie visitors are not required by regulation to be informed of potential health risks to an embryo / fetus prior to gaining access to the radiological controlled area (RCA). Your _

concern was substantiated, howeve, no violations of regulatory requirements were identified. .

This concludes the staff's activities regarding this matter. If you have any questions, you may contact me at 1-800 577 8510 or (404) 331 0335 or by mail at P.O. Box B45 Atlanta, GA, 30301.

Sincerely.

(Original signed by K. P. Barr)

Kenneth P. Barr, Chief Plant Support Branch Division- of Reactor Safety ~

Certified Mail No. Z 238 518 025 '

RETURN RECEIPT REQUESTED -

Enclosures:

1. Allegation Evaluation Report

~~ 2. Report Nos. 50 335/97 02 ~

and 5&489/97 02 bec w/encls: 0. DeMiranda, EICS (Signed Letterhead & E Mail

For previous concurrence see attached page orFItt RIf:0RS RIf DRS RI1 ORP

$1GNATLRE EAME G541yers* K8arr* CJulian*

DATE M/ / 97 N/ / 97 H/ / 97 H/ / 97 N/ / 97 N/ / 97 COPY? YE$ NO YES NO YES NO YES No YES NO YES N0 tttICIAL RECORD COPY: LIC5

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o

SUBJECT:

RII 97 A 0015 FEMALE VISITORS WERE NOT BEING INFORMED Ddb L MONITORING OF AN EMBRY0/ FETUS PRIOR TO GAINING ACCESSETO k RADI0 LOGICALLY CONTROLLED AREA (RCA)

F tl D This refers to our letter dated February 14, 1997, in wh fi we advised you f -

that we were <:ontinuing our review of the concern you ressed regarding -

0 female visitors not being informed about monitoring ~ n embryo / fetus prior to NucyearPlant.aining access to the radiologically controlled area (RCA) at the St. Lucie Our inspection regarding this matter has been ompleted and our findings are documented in the enclosures to this letter / Female visitors not regoired by

regulation to be informed of potential he to gaining access to the radiological c .n~pTth risks(RCA).

to an embryo / fetus prior trolled area Your concern was substantiated, however, no. violations ,, f regulatopf requirements were identified. ,

This concludes the staff's acti ties regarding this matter. If you have any questions, you may contact me a 2 800 577 8510 or (404) 331 0335 or by mail' at P.O. Box 845, Atlanta, GA. 3 301.

/

/ Sincerely, P

l .

Kenneth P. Barr, Chief ,

Plant Support Branch Division of Reactor Safety Certified. No. Z 238 518 025 '

RETURN T REQUESTED Enci es: 1. Allegation. Evaluation Report m.

2. Report N5h. 50 335/97 02 and 50 389/97 02 cc w/encls: 0. DeMiranda. EICS (Signed Letterhead & E Mail WFitf R'ffMtt Rf f :!Rt , Rff!RP!

5""

NAME G$alyers [}<Y rr uti DATE N / / B7 N / ) / 97 N/ / 97 N/ f 97 H/ / 97 N/ / 97 l COPY 7 MS ((NO) R$ [NO) US -[NO) MS NO MS h0 MS NO LMILIN. HtCORD-65PY: LIC5 V

)

RII 97 A 0015 ALLEGATION EVALUATION REPORT ALLEGATION RII 97 A 0015 FENALE VISITORS NOT BEING INFORNED OF NONITORING OF AN EERYO/ FE GAINING ACCESS TO THE RADIOLOGICAL CONTROLLED AREA (RCA)

ST. LUCIE NUCLEAR PLANT DOCKET NOS. 50-335 AND 50-389 CONCERN:

The beingconcerned informed individual (CI) ex)ressed a concern about female visitors not of the potential 1ealth risks and monitoring of an embryo / fetus prior to gaining access to the radiological controlled area (RCA). ~

4 DISCUSSION:

Section 19.12 of Title 10 of the Code of Federal Regulation establishes requirements for instructions to workers. It does not specifically address training requirements for members of the public who are visitors to a licensee facility.

Section 20.1301(a)(1) of Title 10 of the Code of Federal Regulation requires licensees to conduct operations such that the total effective dose equivalent to individual members of the public does not exceed 100 millirem in a year.

Paragrap (b) of that section requires that the limit of 100 mrem a year for members of the public remains in effect, even if the licensee permits a member of the public access to the controlled areas of the site (plant).

Section 20.1208(a) of Title 10 of the Code of Federal Regulation establishes a limit of 500 mrem / term for declared pregnant woman due to occupational exposure.

The ex>osure limit in 20.1301(a) and (b) of 100 mrem a year for a member of the pu)lic is more limiting than the exposure limit of 500 mrem / term for a declared pregnant woman.

The NRC inspection regarding the above concern is documented in NRC Inspection Report Nos. 50 335/97 02 and 50 389/97-02, Section R1.1.

CONCLUSION:

The occupational dose limit of 500 mrem / term for a declared pregnant worker only applies to women who have declared their pregnancy and who receive an occupational dose as a result of their exposure to. radiation while performing their assigned duties.

Enclosure 1

- . . - - . - - _ = . - _ - - . - - . - - . _- ..- . - .- ..

2 RII 97 A 0015 Visitors, who are members of the public, must be controlled so as to not receive radiation exposure in excess of 100 mrem per year. Therefore, a visitor's exposure must be controlled to less than the occupational dose of a declared pregnant worker.

The concern was substantiated in that female visitors to the St. Lucie Nuclear Plant are not informed of the potential health risks to an embryo / fetus.

However, the inspectors concluded that there were no specific training requirements for female visitors to a licensee's site. No violations of regulatory requirements were identified. This allegation is closed.

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Enclosure 1

ORA Fax:404-562-4766 Feb 6 '98 11:44 P.51 i

April 12,1997 _ _ _

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a CASE NO: Ril.37-A-0015 -

FACILITY: ST. LUCIE EMPLOYER: FP&L l h OCCUPATIO

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/__ DOL COMPLAINT: YES ( ) NO (v) 01 INVESTIGATION: YES () NO ( v)

ERA No: 01 CASE NO:

l ADDITIONAL INFORMATIONIOTHER QONTACTS .

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CASE NO: RII 97 A.0015 FACILITY:St. Lucie CONCERN NO: (1)

DOCXET NO:50d$ 50 389 .

AL1EGER:

EMPLOYER:FP&L ADDRESS:

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HOME PHONE.: ( ) ~

WORK PHONE: (') - MTE cE!VED: January 19,1997 b~

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~Y Miel IS*THE" ALLEGATION? ?.".'..

Alimer stated 1

.- mon 1<:orin af:an; hat he had concerns about female visitors < not beindeformed about eneryo/ fetus prior to gaining access to-de Radio 1pgical Controlled Area (RCA

_3 _ . .

WHAT IS THE REQUIREMENT / VIOLATION?

The alleger Procedure. H?P-30.provided Appendix 5.me withOftwo Monitoring The appendices Embryo rocedure. to licensee

!kalth Physics

. . ., states 'All p/ Fetu xrsonnel being issued dosfemales (with the exception of female NRC inspectors) shall Sign Form provided,to tle inspector.tmetry. Appendix 10. Access To h RCA By Visitors, was also-

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WHERE IS IT LOCATE 0?

St. Lucie M E DID IT OCCUR 7 ~

This concern was raised 1/19/97

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0W/WHY DID IT OCCUR?

ac information.

WHAT EVIDENCE CAN BE EXAMINED?

HPP-30 DID WE INDIVIDUAL EXPRESS A CONCERN TO THE LICENSEE 7 -

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g.gT Ik IHE STATUS OF THE LICENSEE'S ACTION 5?

I According required.

to the alleger, t2ie' licensee is satisfied that nathing additIo'.nal is Allsger ir, formed of HRC identie protectiin YXX N Did alleger request confidentiality 7....... policy?...

.........., Y . M

' 01d the alleger object to 6 licensee / state referral?... I NXX Was the alleger informed of 00L reporting requiremitntsi M N '

Tvbe of-RMulited' Activity; (it)X~ Reactor b) Vendor (ci~~fEterfals (d)_ Safeguards (t) other: ~"

Ask all above questions, do not leave any blanks.

RII/sc P.O. BOX 845 Atlanta. GA me: complete one sheet for each 1ssue. Forward this 10T1l1 to:

. Do not retain any file copies subsequent to receipt by SAC.

SAC phcne numbers are (404) 3.11-4t03 & 1314194.

PREPARED BY:Joel T, ,Hunday 1 l Infer. m .i..i .u - - - ~ ~ - -- DATE PREPARED:01/21/97 i. __,

i.uccordx:: vn the Frcc:km of Information AC !'.en$cg[,y y

ORA Fax: O P562-4766 Feb 6 '93 11:37 P,40

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<W/:5)J M k N Ce nIh0ATI'ON M ~. l CASE NO: RII 97-A-0015 FACILITY:St. Lucie -

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, ADDITIONAL INFORMATION Alleger stated that he brought this concern t not a problem. who told him that this was" l 2

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tate e was i

epen should be made of the practice of aho2n n without querytmj;them as to their status vis-a-vis pregnancy.g Addi 551sitors on sitek illy, the CI %

stated that a disconnect existed within HPP-30: Appendix 5 states that all females d (except female NRC ins to the same procedure,pectors) shall sign a form regarding pregnancy, while Appendix 10 discussion of pregnant females.

which delineates requirements for visitors contains no

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ACTION REQUIRED O

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PREPARED 1Y: Joel T. Munday_. - DATE PREPARED: +

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I ALLEGATION REPORT fCASENO: RII 96 A 0130 FACILITY: St. Lucie fCONCERNNO: (1) DOCKET NO: 50-335..389 EMPLOYER: Florida Power and Light ADORESS TITLE: Excessi"e Hours of Work HOME PHONE: ( )

I I DATE RECEIVED: 6/11/96 l

I .

E ALLEGAT l

l '.)

D I E REQUIREMENT / VIOLA, TION? Technical Specifications (6. 2 u el n f l WHERE IS IT LOCATED? Records available from Human Resources and Security.

l WHEN DID IT OCCUR? Now. Throughout outage.

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_1 j HOW/WHY DID IT OCCUR? Pressure exerted by management to complete outage.

l WHAT EVIDENCE CAN BE EXAMINED? Gate Records. I(lo tr4 2.7% @N N .

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!g DID T XPRESS A CONCERN T LICENSEE

(

j WHAT IS THE STATUS OF E E LICENSEE'S ACTIONS? None i SRI recommends that we request gate records for all first line maintenance supervision

! immediately and compare hours to TS requirements. Records should then be compared to

! Human Resources;.r.ecords. These personnel (particularly I&C) perform safety related j

functions' including troubleshooting and repairing safety related component's directly.

l Alleger informed of NRC Identity protection policy?, YXX N I Did alleger request confidentiality ?. . . . . ... .... Y NH l

Did the alleger object to a licensee / state referral?.., Y~ N

, Was the alleger informed of DOL reporting requirements? YXX N_

Type of Reculated Activity: (a)XX Reactor b) Vendor (c) Materials (d) Safeguards (e) other:

Ask all above questions, do not leave any blanks. Complete one sheet f6r each issue. Forward this form to:

2 RII/ SAC. P.O. BOX 845 Atlanta. GA 30301. Do not retain any file copies subsequent to receipt by SAC.

, SAC phone numbers are (404) 331-4193 & 3314194.

l PREPARED BY: Mark S. Miller

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! DATE PREPARED: ,

l i..m . .m m Pi ; c::ed ..las d:Ted j b Crdr.:s with tha ,90 im ci!nformation th

. Act, excmptbns'7C v l folA. 97-OP t/

UNITEo STATES

,f.#e.2 582g%, NUCLEAR REGULATORY COMMISSION d

. O REGloN 11

,;* 9 101 MARIETTA STREET. N.W., SUITE 2900

7. l ATLANTA. oEORGIA 303234199

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August 24, 1996

?>a GA

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SUBJECT:

Ril 130 - QUESTIONABLE OVERTIME PRACTICES y ,

gl.

This refers to our letter dated June 19, 1996, in which we advised you that we _

would review the concern you expressed regarding working excessive hours at -

Florida Power and Light (FP&L) Company's St. Lucie facility. .

Our inspection regarding this matter has been completed and our findings are documented in the enclos~ures to this letter. Based on the information provided, we were .able to partially substantiate the alle'gation. There were two violations of regulatory requirements identified.

This concludes the staff's activities regarding this matter. If you have any questions, you may contact me at 1-800-577-8510 or (404) 331-5509 or by mail at P.O. Box B45, Atlanta, GA 30301.

Sincerely, err . L ndis Chie Branch 3 Division of Reactor Projects .

Certified' Hail' N6. P 343 383 495 e RETURN RECEIPT REQUESTED .

Enclosures:

1. Allegation Evaluation Report

2. Report Nos, 50-335/96-09 and 50-389/96-09

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Enclosure 1 ALLEGATION EVALUATION REPORT ALLEGATION RII-96-0130 QUESTIONABLE OVERTIME PRACTICES ST LUCIE NUCLEAR PLANT DOCKET NOS. 335 AND 389 CONCERN: The concerned individual stated that personnel are being coerced to work excessive hours to finish the outage. Time is not being recorded on time sheets, though a true accounting of the hours worked can be derived from gate access. Many examples were given of individuals that had worked excessive overtime.

DISCUSSION:

08.1 Control of Overtime (71707. 40500) ~

a. Scope The inspector reviewed the licensee's control of overtime for the period of May 13 through June 13. The inspector obtained gate logs for 26 individuals. The selected individuals were chosen from the licensee's maintenance, engineering, planning, and management organizations based upon their involvement in outage activities and the inspector's under-s'tanding of the activities under their cognizance. From the results obtained (which demonstrated time spent on site), the inspector reduced the inspection population to five individuals based upon indications of excessive hours. The individuals in question included supervisors and engineers with responsibilities for safety-related work.

As acceptance criteria, the inspector reviewed TS 6.2.f, which required that the hours expended by personnel performing safety-related functions be limited, with an objective that personnel work a normal 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months day, 40 hour4.62963e-4 days 0.0111 hours 6.613757e-5 weeks 1.522e-5 months week while the plant was operating. The TS observd that substantial amounts of overtime might be required during extended periods of shutdown for refueling, and established guidelines for these periods. Tho TS stated"

. . . on a temporary basis the following guidelines shall be followed:

a. An individual should not be permitted to work more than 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months straight, excluding shift turnover time,

b. An individual should not be permitted to work more than 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months in any 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period, nor more than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months in any 48 hour5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months period, nor more than 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months in any 7-day period, all excluding shift turnover time.

2

c. A break of at least 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months should be allowed between work peri-ods, including shift turnover time . . .

. . . Any deviations from the above guidelines shall be authorized by the Plant General Manager or his deputy, or higher levels of management, in accordance with established plant procedures and with documentation of the basis for the deviation." The ins,.ector reviewed AP 0010119, Rev

14. " Overtime Limitations for Plant Personnel," and found that the procedure appropriately implemented the TS requirements,

b. Findings The inspector found that the licensee deviated from TS guidelines for the control of overtime without the prior (or subsequent) approval from senior plant management. Of the five individuals focused on as a result of gate logs, the following information was obtained from timesheets (violations of the requirements were cited only for excesses of require-ments which had not received appr' 11 per AP 0010119): _

Individual Violations of 72 Violations of Violations of 16 Ilour Requirement 24/48 Hour Hour Requirement Requirement A 3 0 0 B 0 0 0 C 5 1 0 D 14 2 0 E 16 12 3 Total 38 15 3 The instances identified above, in which TS guidelines were exceeded, and for which the TS-required approvals for the deviations were not obtained, collectively represent a vialation (VIO 335,389/96-09-01,

" Failure to Control Overtime").

While violations were identified, the inspector also noted that signifi-cant differen:es existed between timesheet records, which divided time between TS and non-TS (e.g. shift turnovers) categories, and gate records, which indicated total time on site. For the 5 individuals highlighted above, numerous instances of differences between-total time on. site and timesheet-indicated time on site existed, with differences frequently exceeding one and two hours and, at times, exceeding several hours. The most time spent continuously on site was noted to be approximately 26 hours3.009259e-4 days 0.00722 hours 4.298942e-5 weeks 9.893e-6 months .

The inspector discussed the results above wit'h the affected parties to ascertain the reasons for the excessive use of overtime and for the l

3 differences between gate logs and timesheets. Rcr onses were mixed.

l Regarding the heavy use of overtime, several respondents pointed out that the project that they had been working was adversely affected by the loss of several key personnel which reduced the depth of knowledge on the associated job. Several stated that the diverse activities on both units (due to the outagt on Urit I and the recent trip of Unit 2) had placed increased demands on their time.

In discussing the method for completing timesheets, the inspector found that a lack of uniformity existed. Some respondents treated work periods (as described on the timesheet) as any work performed on a given calendar day. By applying this approach, the potential existed for the work hours recorded for a given day to represent a composite value of two work periods if one (or more) of the work periods extended across midnight. The potential result of this type of accounting was that the true length of a work period, as referenced in is, would not be accu-rately reflected on timesheets, confounding the ability to maintain an accurate count of daily, 48 hour5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months and 7-day totals. _

With regard to not obtaining the appropriate deviation approvals for time worked in excess of the guidelines, sev1ral workers stated that they believed that obtaining a deviation provided a blanket authoriza-tion for overtime spent on the project for which the deviation applied.

The inspector noted that the AP was not specific as to whether a deviation request was required for each planned deviation from the guidelines or whether it applied to the job which was described on the request. The inspector discussed this issue with the Plant General Manager, who stated that it was his expectation that a deviation request be filed for each planned deviation of the guidelines (the implication being that a series of work periods for which each period led to violations of one or more guidelines should each be documented on separate requests). The inspector had requested any deviation requests associated with the personnel audited for the subject time period. Two were identified which addressed themselves to 3 of the personnel. The deviations covered by these deviation requests were not considered in the summary table above.

AP 0010119 required that department heads perform a monthly review of assigned overtime to assure that excessive overtime was not assigned.

However, step 8.5 of the procedure, which directed that department heads perform a monthly review to ensure that excessive overtime hours were not assigned, was not specific as to how such a review should be performed (e.g. populction size, sources of information). The inspector noted that this was the second weakness identified in the procedure (the first being a lack of specificity on when deviation requests were required).

Technical Specification 6.2.f requires, in part, that deviations from overtime guidelines be approved in accordance with established proce-dures and that controls be included in establis'hed procedures such that individual overtime be reviewed monthly by the Plant General Manager or his designee to assure that excessive hours have not been assigned. The

n 4

inspector concluded that the failures of the subject proceduro to provide an appropriate level of detail resulted in a procedure which was inadecuate to satisfy the requirements of the TS. Consequently, the procecure inadequacies constitute a violation (VIO 335,389/96-09-02,

" Inadequate Procedure for Managing Overtime").

Independent of this inspection (and unknown by the inspector at the time), the licensee's QA organization )erformed an audit of overtime usage for the period from May 5 throug1 18. A population of 100 plant personnel was selected at random for the audit. QA reviewed gate logs for the sample >opulation and applied criteria which assumed a one half hour lunch brea( and accepted turnover periods to reach the following criteria for determining whether guidelines had been exceeded:

. No more than 17.5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months in 1 day.

No more than 27 hours3.125e-4 days 0.0075 hours 4.464286e-5 weeks 1.02735e-5 months in a 48 hour5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months period No more than 82.5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months in a 7 day period

An 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months break between wcrk periods. _

QA determined that 13 percent of their population exceeded the criteria at least once and that 8 percent exceeded the criteria at least twice.

QA informed management of their findings in this area on June 6. As a result, the Site Vice President and the PGM discussed the problem with plant staff at morning meetings to stress expectations for personal accountability in this area. On June 19, the PGM issued a letter to department heads restating the overtime guidelines and stressino personal accountability on the issue. The inspector noted that, with respect to immediate corrective actions,-23 examples of unapproved deviations existed in the inspector's sample from June 8 through 13.

Maintenance Valve Group Overtime Usage: the above inspection consisted of a review of gate logs for approximately 25 individuals, including 2 from the Maintenance Valve Group. As a result of the initial review, 5 individuals were selected for more detailed reviews of time sheets.

While the Valve Group personnel were not selected as candidates for time sheet reviews, it was noted that these personnel were typical of others in the sample, in that gate records indicated that excessive hours were worked.

c.

Conclusion:

As a result of this inspection, the inspector concluded the following:

Overtime usage for the period May 13 through June 13 exceeded TS

. guidelines for a number of personnel including the valve group.

. The licensee failed to effectively control overtime as required in AP 0010119, Rev 14, " Overtime Limitations for Plant Personnel," in that deviation requests were neither prepared nor approved for the majority of deviations identified.

+

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5 AP 0010119 was' unclear in'its expectations, both for when a

. deviation request was required and for how reviews of overtime usage were to be executed, The requirement for monthly reviews of overtime usage, detailed in '

AP 0010119, was~ ineffectively implemented.

Personnel have, at times, worked hours which were not recorded'on timesheets.

CONCLUSION:

As a result of the overall inspection effort, 53 examples of exceeding TS guidelines without obtaining prior management approval were identified. Two-violations were cited in Inspection-Report 96-09, one for the multiple examples of excessive, unapproved, overtime, and one for an inadequate ;

procedure for managing overtime. _

_The concerned individual stated that personnel are being coerced to work' excessive hours to finish the-outage. Time is not being recorded on time sheets, though a true accounting of the hours worked can be derived from gate access. The inspector discussed the results above with the affected parties to ascertain the reasons for the excessive use of overtime and for tne' differences between gate logs and timesheets. Responses were mixed. Regard- H

-ing the heavy use of overtime, several_-respondents pointed out-that the 'l project that they had been working was adversely affected by the_ loss of: l several key personnel which reduced the. depth of knowledge-on.the associated -l job. Several stated that the diverse. activities on-both units (due to the:

outage on Unit I and the recent_ trip of Unit 2):had placed increased ~ demands on their time. No evidence was observed which indicated coercion to work overtime or to not record worked hours on time sheets, although not recording 1 hours1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months on the time sheets was practiced by some personnel. - This allegation was partially substantiated.

-_These allegations are considered closed.

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'l i August 27,1996

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ALLEGERUMtESS: g, 3g)ppj CHANGE OF ADDRESS '

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l a b HOME PHONE: (

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CASE NO: Ril-96-A 013b FACILITY: ST. LUCIE <

b f EMPLOYER: FP&L

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! DOL COMPLAINT: YES () NO(x)

ERA NO: Of INVESTIGATION: YES () NO (/)

Of CASE NO:

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ADDITIONAL INFORMATIONIOTHER CONTACTS Reference allegation Ril-96-A-0133. _ .

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! l Infctmtica in this record was deleted in. Ic:c.-dn:e with th: Fraadom of Informatiarf Act. exe.plions - M FOIA- 7WM !

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ML20202E061

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ML20202E061

Text

Enclosures:

SUBJECT:

Enclosures:

SUBJECT:

SUBJECT:

Enclosures:

Conclusion:

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