ML20206U316

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Forwards Evaluation of Matter Described in Ltr Re Byron Station.Use of Overtime Since 1995 Has Been Consistent with No Notable Trend;Use of Overtime Has Met Expectations for Implementation of TSs
ML20206U316
Person / Time
Site: Byron  Constellation icon.png
Issue date: 12/08/1998
From: Graesser K
COMMONWEALTH EDISON CO.
To: Clayton H
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20206U278 List:
References
NUDOCS 9905250161
Download: ML20206U316 (4)
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. L e D . .N M L ML b l U.% 111 n$ U 2 d Onnmonweahh I s' Compam 11 3 ren Generating St.. ..in MO North Gcrman ( hurc h Ro.nl Dyron. II. 610109794 Tet Hi 4234-5 4 41 December 8,1998 l

H. Brent Clayton Region 111 Enforcement Officer l U.S. Nuclear Regulatory Commission Region ill 801 Warrenville Road Lisle, IL 60532-4251 1

Subject:

Byron Station Response to Request for Evaluation - NRC Tracking No. 98-A-0165 l

Reference:

Letter from H. Brent Clayton, (U.S. N.R.C) to O. D. Kingsley, (Commonwealth Edison Company) dated October 30,1998.

Dear Mr. Clayton:

Pursuant to your request, we are providing you a copy of our evaluation of the matter described in the referenced letter. It should be noted that this is a partial response to the requested information. As requested, this response is not being submitted on the station docket. As discussed in a teleconference held between representatives of Commonwealth Edison (Comed) Company and the NRC on November 20,1998, the submittal date for this evaluation was extended from November 27,1998 to December 8,1998, in a follow-up discussion with Mr. H. Brent Clayton, on December 8, 1998, the NRC was notified that supplementalinformation would be provided by i December 22,1998. I The evaluation was conducted independently by the Comed Corporate Nuclear Oversight and Security Departments. We have determined that the investigation was of sufficient depth and scope to address the issues thus far. In summary, and as detailed in the attachment, use of overtime since 1995 has been consistent with no notable trend; use of overtime has met expectations for implementation of the Technical 3$ Specifications, and; corrective actions associated with the January 1995 NRC violation 28 have been effective.

$ If you have any questions about the attached information or questinns related to this W

matter, please contact me at (815) 234-5441 extension 3600.

@$ Sincerely, 88 "0 0 **

i i EP *

[r K. L. Graesser Site Vice President i Byron Station

Attachment:

Evaluation Report NRC Tracking No. 98-A-0165 (pAbbateno\8658zz. doc) e' l$ttfq & W 09asc[w(oWi nns Wf e h

o.3/24/99 17:19 FAX 630 515 1078 U.S..NRc REGION Ill @ 024 Attachment Evaluation NRC Tracking No. 98-A-0165

1. INTRODUCTION:

In a letter dated October 30,1998, the U. S. Nuclear Regulatory Commission (NRC)

Region lil forwarded the following information to Comed for evaluation.

"An individual stated a belief the licensee is not in compliance with Generic Letter 82-12,

' Nuclear Power Plant Staff Working Hours,' because the licensee has routinely -

increased the amount of overtime for the operations department reactor operators over the past several years. The individual stated that it doesn't appear that any effort is being made by plant management to improve the increasing amount of routine and excessive overtime required of the operators at the site."

"The individual indicated that the average overtime in 1996 was approximately 150 hours0.00174 days <br />0.0417 hours <br />2.480159e-4 weeks <br />5.7075e-5 months <br />; however, the average yearly overtime in the past 2 years has increased to as much as 500+ hours."

"The individual stated that there was a license class in progress but indicated it would be approximately 18 months before the class could be used to reduce the overtime burden.

In addition, the individual also stated the license class has increased the non-licensed operator overtime."

"There are 27 active reactor operators at the site: however, currently several are assigned to activities not requiring a license to perform the activity."

"The individual also indicated that the site Administrative procedures state that the facility will maintain adequate staff to prevent routine use of overtime."

The NRC also noted that this issue, excessive use of overtime, had been the subject of a violation cited in Inspection Report 50-454/455-94025, issued on January 6,1995.

As requested in the October 30,1998 letter, information is being provided on four specific issues to address the individual's concerns. This evaluation is ongoing and not yet complete. The following discussion provides the current status of the evaluation, it. EVALUATION DETAILS AND CORRECTIVE ACTIONS:

The corporate Nuclear Oversight department, in conjunction with support from the corporate Security department, is conducting an independent evaluation of the information requested in NRC letter dated October 30,1998.

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Issue #1:

l "Please describe the overtime trend for operations personnel. Specifically, provide documentation to support whether the use of overtime since the violation issued by the NRC in January 1995, has been on an increasing or decreasing trend for reactor I

operators, senior reactor operators and non-licensed operators covered by Generic Letter 82-12, and what effect this trend has had on plant operations."

l Response

  • Overtime usage, within the operations department, since the NRC violation was issued i in January 1995, has average 372.8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> per person per year. This is the yearly average for 1996 through 1998. The 1998 overtime is based on actual hours worked through the month of October. The concemed individual stated that average overtime in 1996 was approximately 150 hours0.00174 days <br />0.0417 hours <br />2.480159e-4 weeks <br />5.7075e-5 months <br /> per person. The actual average overtime usage within the entire operations department for 1996 was 340.6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> per person. The overtime hours attributed specifically to reactor operators, senior reactor operators and l non-licensed operators in 1996 was: 462.9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br /> per person per year; 120.2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> per I person per year; and 407.2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> per person per year, respectively. Based on this i review, overtime usage has neither increased nor decreased since the NRC violation  ;

was issued in January 1995, but has remained fairly constant throughout the period.

l We will continue to evaluate what effect the use of overtime may have had on plant operations and will discuss the conclusion in our supplemental response.

Issue #2:

" Describe whether the use of overtime has met both the administrative requirements and management expectations for implementation of the Technical Specification and procedures. Ensure your response addresses whether overtime usage, while it may not l violate the Technical Specification or the Generic Letter, crosses into the realm of

' routine' as described in your Administrative procedure."

Response

The use of overtime at Byron Station meets the administrative requirements and management expectations for implementation of the Technical Specification, as described in BAP 100-7, " Overtime Guidelines for Personnel." We continue to evaluate whether the use of overtime crosses into the realm of " routine" as described in the administrative procedure. This will be discussed in our supplemental response.

Issue #3:

Have the corrective actions implemented as a result of the January 1995 violation been effective?

Resoonse:

The violation cited in NRC Inspection Report 50-454/455-94025 dealt with the failure to properly obtain " initial approval" for overtime guideline deviations prior to the occurrence I

1 of that deviation. In this case, prior approval was not obtained on at least 29 separate occasions out of 300 deviations during the period from August 1,1994 through November 1,1994.

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' A review of Byron Station's Semi-Annual Overtime Deviation Summary reports for the period from ~ January 1995, through June 1998, shows + hat of the 4300 deviations approved during that time,93 deviations (i.e.,2.2%) wue approved after the fact. We will address the effectiveness of the corrective actions in the supplemental response.

Issue #4:

If the concern is true, what actions have or will be taken to alleviate the routine and excessive use of overtime, l Resoonse:

The final conclusion regarding this concern will be provided in our supplemental .

response.

I lil. CONCLUSION:

The corrective actions to the NRC violation cited in NRC Inspection Report I 50-454/455-94025 were effective in reducing the number of times overtime deviations  !

were not approved in advance. Further review of the corrective actions will be addressed in the supplemantal response. The question of whether or not this overtime usage crosses into the realm of " routine" and what effect the use of overtime has had on plant operations continues to be reviewed.

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