ML20206U322
| ML20206U322 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 12/22/1998 |
| From: | Graesser K COMMONWEALTH EDISON CO. |
| To: | Clayton H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20206U278 | List: |
| References | |
| NUDOCS 9905250165 | |
| Download: ML20206U322 (6) | |
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i December 22,1998 l
H. Brent Clayton Region 111 Enforcement Officer U.S. Nuclear Regulatory Commission Region ill 801 Warrenville Road Lisle, IL 60532-4251
Subject:
Byron Station Supplemental Response to Request for Evaluation -
NRC Tracking No. 98-A-0165
References:
(1) Letter from H. Brent Clayton (U.S. NRC) to O. D. Kingsley (Commonwealth Edison Company) dated October 30,1998 (2) Letter from K. L. Graesser (Commonwealth Edison Company) to H. Brent Clayton (U.S. NRC) dated December 8,1998
Dear Mr. Clayton:
Pursuant to your request, we are providing you a complete copy of our evaluation of the matter described in Reference 1. 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 the initial evaluation was extended from November 27,1998 to December 8,1998. A partial response was submitted by letter dated December 8,1998, (Reference 2). In a follow-up discussion with Mr. H. Brent Clayton, on December 8,1998, the NRC was notified that supplemental information would be provided by December 22,1998. Both the initial and supplemental evaluations are included in the attachment for completeness.
i The evaluation was conducted independently by the Comed corporate Nuclear Oversight and Security Departments. We have determined that the evaluation was of sufficient depth and scope to address the issues. In summary, and as detailed in the attachment, use of overtime since 1995 has been consistent with no notable trend and I
has not had an adverse effect on plant operations. Use of overtime has met expectations for implementation of the Technical Specification requirements and has not crossed into the realm of " routine." The corrective actions associated with the January 1995, NRC violation. regarding the control of overtime, have been effective.
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December 22,1998 H. Brent Clayton -
4 Page 2 If you have any questions about the attached information or questions related to this matter, please contact me at (815) 234 5441 extension 3600.
Sincerely, M
K. L. Graesser Site Vice President Byron Station
Attachment:
Evaluation Report NRC - Tracking No. 98-A-0165
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E OU 26/@@ EYtBT FAE 69@ 515 1078 L.S..NRC REGlo.N 111 yr; o 19 Attachment Evaluation NRC Tracking No. 98-A-0165 I.
INTRODUCTION in a letter dated October 30,1998, the U. S. Nuclear Regulatory Commission (NRC),
Region 111, forwarded the following information to Commonwealth Edison (Comed)
Company for evaluation.
j "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 I
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 t3 approximately 18 months before the class could be used to reduce the overtime I
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."
i ne NRC also noted that inis 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.
II.
EVALUATION DETAILS AND CORRECTIVE ACTIONS The corporate Nuclear Oversight Department, in conjunction with support from the corporate Security Department, conducted an independent evaluation of the information requested in NRC letter dated October 30,1998. As requested, information is being provided.on four specific issues.
Issue #1:
"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
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operators, senior reactor operators and non-licensed operators covered by Generic Letter 82-12, and what effect this trend has had on plant operat!ons."
InitialEvaluation Overtime usage, within the operations department, since the NRC violation was issued in January 1995, has averaged 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 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 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 review, overthne usage has neitherincreased nor decreased since the NRC violation was issued in January 1995, but has remained fairly constant throughout the period.
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.
1 Supplemen+alEvaluation A review of appropriate Licensee Event Reports and Root Cause Evaluations dealing with human performance errors, as well as the results of other independent reviews of station performance, was performed to determine what effect the use of overtime may have had on plant operations. Based on this review,it was concluded that overtime usage has not adversely impacted operation of the Byron Station.
Issue #2:
" Describe whether the use of overtirr.e has met both the administrative requirements i
and management expectations ferimplementation of the 10chnical Specification and procedures. Ensure your respouse addresses whether overt me usage, while it may i
not violate the Technical Specif cation or the Generic Letter, crosses into the realm of
' routine' as described in your Administrative procedure."
InitialEvaluation The use of overtime at the Byron Station meets the administrative requirements and management expectations for implementation of the Technical Specifications, as described in Byron Administrative Procedure (BAP) 100-7, " Overtime Guidelines for i
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.
SupplementalEvaluation Procedure BAP 100-7, " Overtime Guidelines for Personnel," states that overtime will not " routinely" be used to " compensate for inadequate staffing." In this context, the overtime usage at Byron Station does not cross into the realm of routine. Sufficient s
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o staffing has been and continues to be maintained to support the operational requirements of the station.
The majority'of the overtime from 1996 through November 8,1998, was accumulated during the support for unit outages and is not considered routine. In 1997, the peak year for overtime, there were a total of seven outages: six forced outages and one refueling outage. The first half of 1998 had an above average amount of overtime; however, this is attributed to the back-to-back refueling outages. The Unit 1 Steam Generator Replacement outage began in November 1997, and concluded in March of 1998. The Unit 2 refueling outage started the next month and was completed in May 1998. The trend for the remainder of 1998 shows a dramatic decline in overtime hours.
Issue #3:
"Have the corrective actions implemented as a result of the January 1995 violation been effective?"
InitialEvaluation The violation cited in NRC Inspection Report 50-454/455-94025 dealt with the failure to property obtain " initial approval" for overtime guideline deviations prior to the occurrence 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.
' A review of Byron Station's Semi-Annual Overtime Deviation Summary Reports, for the period from January 1995, through June 1998, shows that of the 4300 deviations approved during that time,93 deviations (i.e.,2.2%) were approved after the fact. We will address the effectiveness of the corrective actions in the supplemental response.
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SupplementalEvaluation The after the fact overtime deviation approval rate was reduced from 9.7% in 1994, to 2.2% in the 1995 to 1998 timeframe. Based on this reduction, it is concluded that the corrective actions, taken in response to the violation cited in NRC Inspection Report 50-454/455-94025, have been effective in reducing the occurrences of after the fact overtime approvals. Byron Station continues to work toward a goal of zero after the fact overtime approvals. In a November 1998 Department Heads meeting, the Byron j
Station Manager re-emphasized the need to justify and pre-approve all requested overtime.
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- lf the concern is true, what actions have or will be taken to alleviate the routine and excessive use of overtime."
InitialEvaluation The final conclusion regarding this concern will be provided in our supplemental response.
SupplementalEvaluation Based on this evaluation, we have concluded that the use of overtime at Byron Station has been, and continues to be, controlled in a manner which ensures compliance with the station's Technical Specifications as implemented by procedure BAP 100-7. The use of overtime has not adversely impacted the operations of the station nor has the station used overtime to compensate forinradequate staffing. The use of overtime is, however, a recognized concem of the Nuclear Generation Group (NGG). Overtime is used by NGG managoment as an indicator of the inefficiencies in the processes used
' to accomplish daily v ork activities, and the overall effectiveness of the NGG improvement initiati,res. We expect that as inefficiencies are reduced or eliminated, the use of overtime wil; also be reduced.
111.
CONCLUSION Initial Conclusion The corrective actions to the NRC violation cited in NRC Inspection Report 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 supplemental 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.
I SupplementalConclusion:
It is the conclusion of this evaluation that the use of overtime at Byron Station has been, and continues to be, controlled in a manner consistent with safe plant operations.
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