ML20207B875
| ML20207B875 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 05/18/1999 |
| From: | Shirley Ann Jackson, The Chairman NRC COMMISSION (OCM) |
| To: | Dingell J, Klink R, Markey E HOUSE OF REP. |
| Shared Package | |
| ML20207B880 | List: |
| References | |
| NUDOCS 9906020143 | |
| Download: ML20207B875 (12) | |
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l [e Osag% UNITED STATES
,. &" . 3 NUCLEAR REGULATORY COMMISSION WASHINGTON. D.C. 20555-0001 e
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CHAIRMAN
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The Honorable Edward J. Markey United States House of Representatives Washington, D.C. 20515 2017
Dear Congressman Markey:
I am responding to your letter dated February 25,1999, expressing concerns that low staffing !
levels and excessive staff overtime may present a serious safety hazard at some commercial nuclear power plants in the United States. In particular, you noted that an article appearing in the February 15,1999, issue of inside N.R.C. stated that some operators at the Byron nucle 8r plant were concerned that the amount of overtime they were being required to work has at times jeopardized plant safety. On behalf of the Commission, I want to assure you that the U.S.
Nuclear Regulatory Commission (NRC) is addressing the specific concerns that have been raised about overtime use at the Byron plant.
In response to your broader concern about specific plant practices and applicable NRC l regulations, the staff has reviewed NRC inspection findings related to staffing and working hours for the past five years and, to the extent practicable, has answered the specific questions itemized in your letter. The responses to your questions are enclosed. Although the data available to the staff did not support answering some of your questions at the level of detail that you requested, I believe the following information addresses your underlying concerns. j e The NRC has attributed few events at nuclear power plants to personnel fatigue.
However, the number of events for which personnel fatigue has been a contributing factor cannot be reported with certainty given the difficulty of making such determinations. Of those events that have been attributed to personnel fatigue, the NRC has found that they were typically of limited safety significance. In all instances automated safety systems or other barriers were available to prevent any safety consequences.
- NRC inspectors have identified several instances each year in which licensee use of overtime appeared to be inconsistent with the general objectives or specific guidelines of the Commission's " Policy on Factors Causing Fatigue of Operating Personnel at Nuclear Reactors." In those instances in which NRC inspectors found indications of fatigued personnel, the inspectors found that safety significance was limited.
- The NRC currently evaluates licensee use of overtime for plant personnel who perform safety-related functions by ensuring that licensees comply with plant technical specifications and administrative procedures that are consistent with the Commission's policy statement. The
! policy sets guidelines for the control of overtime and allows the flexibility for licensees to deviate I from the guidelines when they can justify that such deviations would not result in significant reduction in personnel effectiveness. However, the NRC is revising its overall reactor oversight
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2 process to ensure that the process is more objective and clearly focused on the issues most important to safety. At present, the staff does not anticipate that the new oversight process will include routine review of licensee use of overtime.
In light of the staff's preliminary review of this issue and the anticipated changes in the reactor oversight process, the staff will assess the need to revise the NRC " Policy on Factors Causing Fatigue of Operating Personnel at Nuclear Reactors." In addition, the staff will continue to follow up on safety significant occurrences to determine the root cause, including the potential contribution of personnel fatigue, and make adjustments to our regulatory program where appropriate.
I trust that this letter and the enclosed responses adequately address your concerns.
Sincerely, j- m.
Enclosure:
Questions and Answers
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h.4 UNITED STATES NUCLEAR REGULATORY COMMISSION l WASHINGTON, D.C. 20655-0001 e
May 18, 1999 k . . . . . j/
CHAIRMAN The Honorable John D. Dingell United States House of Representatives Washington, D.C. 20515-2017
Dear Congressman Dingell:
I am responding to your letter dated February 25,1999, expressing concerns that low staffing levels and excessive staff overtime may present a serious safety hazard at some commercial nuclear power plants in the United States. In particular, you noted that an article appearing in the February 15,1999, issue of inside N.R.C. stated that some operators at the Byron nuclear plant were concerned that the amount of overtime they were being required to work has at times jeopardized plant safety. On behalf of the Commission, I want to assure you that the U.S.
Nuclear Regulatory Commission (NRC) is addressing the specific concerns that have been raised about overtime use at the Byron plant.
In response to your broader concern about specific plant practices and applicable NRC regulations, the staff has reviewed NRC inspection findings related to staffing and working hours for the past five years and, to the extent practicable, has answered the specific questions itemized in your letter. The responses to your questions are enclosed. Although the data available to the staff did not support answering some of your questions at tne level of detail that you requested, I believe the following information addresses your underlying concerns.
e The NRC has attributed few events at nuclear power plants to personnel fatigue.
However, the number of events for which personnel fatigue has been a contributing factor cannot be reported with certainty given the difficulty of making such determinations. Of those events that have been attributed to personnel fatigue, the NRC has found that they were typically of limited safety significance. In all instances i automated safety systems or other barriers were available to prevent any safety l consequences, e NRC inspectors have identified several instances each year in which licensee use of l overtime appeared to be inconsistent with the general objectives or specific guidelines of the Commission's " Policy on Factors Causing Fatigue of Operating Personnel at Nuclear Reactors." In those instances in which NRC inspectors found indications of !
fatigued personnel, the inspectors found that safety significance was limited.
The NRC currently evaluates licensee use of overtime for plant personnel who perform safety-related functions by ensuring that licensees comply with plant technical specifications and !
administrative procedures that are consistent with the Commission's policy statement. The l policy sets guidelines for the control of overtime and allows the flexibility for licensees to deviate from the guidelines when they can justify that such deviations would not result in significant reduction in personnel effectiveness. However, the NRC is revising its overall reactor oversight !
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process to ensure that the process is more objective and clearly focused on the issues most important to safety. At present, the staff does not anticipate that the new oversight process will include routine review of licensee use of overtime.
In light of the staff's preliminary review of this issue and the anticipated changes in the reactor oversight process, the staff will assess the need to revise the NRC " Policy on Factors Causing Fatigue of Operating Personnel at Nuclear Reactors." In addition, the staff will continue to follow up on safety significant occurrences to determine the root cause, including the potential contribution of personnel fatigue, and make adjustments to our regulatory program where appropriate.
I trust that this letter and the enclosed responses adequately address your concerns.
Sincerely, Q =Cs Shirley Ann Jackson
Enclosure:
Questions and Answers i
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't lMay 18, 1999 CHAIRMAN The Honorable Ron Klink United States House of Representatives Washington, D.C. 20515-2017 1
Dear Congressman Klink:
I am responding to your letter dated February 25,1999, expressing concerns that low staffing levels and excessive staff overtime may present a serious safety hazard at some commercial nuclear power plants in the United States. In particular, you noted that an article appearing in the February 15,1999, issue of inside N.R.C. stated that some operators at the Byron nuclear plant were concerned that the amount of overtime they were being required to work has at times jeopardized plant safety. On behalf of the Commission, I want to as5Jre you that the U.S.
Nuclear Regulatory Commission (NRC) is addressing the specific concems that have been raised about overtime use at the Byron plant.
In response to your broader concern about specific plant practices and applicable NRC regulations, the staff has reviewed NRC inspection findings related to staffing and working hours for the past five years and, to the extent practicable, has answered the specific questions itemized in your letter. The responses to your questions are enclosed. Although the data available to the staff did not support answering some of your questions at the level of detail that you requested, I believe the following information addresses your underlying concerns.
- The NRC has attributed few events at nuclear power plants to personnel fatigue. l However, the number of events for which personnel fatigue has been a contributing factor cannot be reported with certainty given the difficulty of making such determinations. Of '. hose events that have been attributed to personnel fatigue, the
) NRC has found that they were typically of limited safrfy significance. In all instances automated safety systems or other barriers were avaliable to prevent any safety
)
consequences. '
- NRC inspectors have identified several instances each year in which licensee use of overtime appeared to be inconsistent with the general objectives or specific guidelines of the Commission's " Policy on Factors Causing Fatigue of Operating Personnel at Nuclear Reactors." In those instances in which NRC inspectors found indications of fatigued personnel, the inspectors found that safety significance was limited.
The NRC currently evaluates licensee use of overtime for plant personnel who perform safety-related functions by ensuring that licensees comply with plant technical specifications and administrative procedures that are consistent with the Commission's policy statament. The policy sets guidelines for the control of overtime and allows the flexibility for licensees to deviate from the guidelines when they can justify that such deviations would not result in significant reduction in personnel diectiveness. However, the NRC is revising its overall' reactor oversight
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2 process to ensure that the process is more objective and clearly focused on the issues most L important to safety. At present, the staff does not anticipate that the new oversight process will )
include routine review of licensee use of overtime.
In light of the staff's preliminary review of this issue cod the anticipated changes in the reactor oversight process, the staff will assess the need to revise the NRC " Policy on Factors Causing Fatigue of Operating Personnel at Nuclear Reactors." in addition, the staff will continue to follow up on safety significant occcrrences to determine the root cause, including the potential contribution of personnel fatigue, and make adjustments to our regulatory program where appropriate.
I trust that this letter and the enclosed responses adequately address your concerns.
Sincerely, f?kj & J : -
Shirley Ann Jacksor-
Enclosure:
Questions and Answers I
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Questions and Answers l
l Question 1 What enforceable regulations are there on staff overtime and shift staffing at NRC licensees?
Why is there no explicit, enforceable prohibition of excessive hours as there is for airline pilots and truck drivers?
Answer l The NRC has no regulation limiting the use of overtime for personnel working at nuclear power i plants. Rather, in 1981 the Commission chose to address the issue of personnel fatigue and l overtime by promulgating the NRC " Policy on Factors Causing Fatigue of Operating Personnel at Nuclear Reactors." The Commission considered a policy statement rather than a rule to be the appropriate regulatory approach because the policy statement set a high-level objective (i.e., to ensure adequate shift coverage without routine heavy use of overtime) while allowing licensees the flexibility to implement programs that accommodated site-specific scheduling x needs.
As noted in your letter, the current version of the NRC policy was transmitted to licensees in 1982 by Generic Letter 82-12," Nuclear Power Plant Staff Working Hours." At the request of the NRC, most nuclear power plant licensees revised their plant technical specifications to require (1) administrative procedures that include guidelines limiting the working hours of personnel performing safety-related functions and (2) documentation of authorized deviations to the working-hour guidelines. Plant technical specifications are a part of the facility operating license, and failure to comply with technical specifications for the control of plant staff working hours has, in a number of instances, resulted in NRC enforcement action.
The NRC has enforceable regulations related to nuclear power plant staffing. Specifically, minimum on-site staffing requirements for licensed operators are specified in 10 CFR 50.54(m). I Plant technical specifications also include minimum staffing requirements for certain categories of personnel, including categories of personnel covered by the NRC " Policy on Factors Causing ;
Fatigue of Operating Personnel at Nuclear Reactors," such as health-physics personnel. It I should be noted that these requirements are directed toward ensuring that adequate personnel are immediately available to operate the plant safely and, as necessary, to respond to abnormal or emergency plant conditions. As a result, these staffing requirements are generally specified !
at the shift level and do not address overall plant stat 1.ng levels, which more directly influence !
the working hours and levels of overtime, i
Question 2 What definitions or standards for " routine heavy use," temporary basis," and "very unusual circumstances" does the NRC use in evaluating plants' overtime usage?
Answer The NRC policy states that enough plant operating personnel should be employed to maintain adequate shift staffing without " routine heavy use of overtime." The NRC has not defined
" routine heavy use"in this context. The general objective of the policy is that personnel work a 40-hour week while the plant is operating. However, the policy provides a limited set of guidelines for controlling overtime that can be used on a " temporary basis." One example of such a guideline follows: "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 /> in any 24-hour period." As stated in the policy, these guidelines are provided for circumstances requiring substantial amounts of overtime (e.g., shutdowns for major maintenance, modifications, or refueling). Although the intent is to indicate that the guidelines are not appropriate for routine scheduling of working hours, the NRC has not further defined " temporary basis" in this context.
The policy recognizes that "very unusual circumstances may arise" that would require deviation from the working-hour guidelines provided for controlling overtime during periods requiring substantial amounts of overtime. Such deviations should be authorized by the plant manager or a designee. The NRC has not further defined "very unusual circumstances" as used in this context, but has provided applicable guidance in the policy by stating that "the paramount consideration in such authorizations shall be that significant reductions in the effectiveness of operating personnel would be highly unlikely." The latter guidance places appropriate emphasis on performance and risk as the ultimate criteria for authorizing deviations.
NRC inspectors have periodically evaluated the use of overtime relative to a plant's technical specifications and the NRC policy statement. Inspectors have evaluated the use of overtime relative to such subjective criteria as a " routine heavy use" and " temporary basis" on a case-by-case basis and have considered such factors as the number of people working overtime, the amount of overtime worked daily, the number of consecutive days that overtime is worked, and the overall duration of the overtime schedule. Determinations as to whether a situation constitutes "very unusual circumstances" have been based, at least in part, on whether the situation could ha'. . been practically foreseen and remedied.
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Ouestion 3 ,
i Are there any examples of errors in performing safety-related functions at U.S. nuclear plants in the past five years which NRC believes may be attributed in part to operator fatigue, staffing levels, or staff overtime. ]
i Answer i The staff searched inspection reports and event reports from 1994 through 1999 (to date) to identify events in which personnel fatigue or staffing may have been a contributing factor.
The staff identified seven events in which personnel error, possibly caused by fatigue, was I identified as a contributing factor. Two of the events involved plant operators and the other events involved members of plant technical staff who were subject to administrative control of overtime. However, the staff notes that it is not able to report with certainty how often events result from personnel fatigue. Several factors contribute to the difficulty in making such determinations, not the least of which is the need to rely, in part, on individuals assessing their own level of fatigue and the extent to which it influenced their performance.
The staff found that those events that could be attributed to personnel fatigue were typically of low safety significance. In all instances, automated safety systems or other barriers were available to prevent any safety consequences. The staff found one event of greater significance because of multiple weaknesses in the conduct of operations associated with the event.
A similar review was conducted for events related to staffing levels. The staff identified three !
instances in which inspectors noted program implementation weaknesses that appeared, in l part, to ue related to staffing levels. These instances appeared to be limited to shortages of personnel with specialized training rather than indications of widespread or long-term staffing deficiencies.
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o Question 4 For all nuclear plants in the U.S. over the past year, with what frequency did safety-related personnel work a) more than eight hours a day (while the plant was operating), b) work more j than 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> a week (while the plant was operating), c) work more than 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> in a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />
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period, d) work 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 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> period, e) work inore than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in a 7 day !
period, or f) have a break between work periods of less than e!ght hours?
Answer (a and b) The NRC does not monitor levels of overtime use that do not meet the threshold for requiring overtime authorization. Consequently, the staff is unable to report the frequency of personnel working in excess of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> a day or 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> a week. There are additional 1 considerations that complicate the response to these two questions. Since the issuance of the I policy statement, nuclear plants have frequently requested, and the NRC has approved, amendments to their plant technical specifications to allow the use of shifts up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> long.
In the case of 12-hour shifts, schedules typically comprise 36- and 48-hour weeks. As a result, personnel frequently work in excess of 8-hour shifts or 40-hour weeks as part of their routine work schedule. Although such schedules do not meet the norma! 8-hour day objective of the policy, plant technical specifications in such cases are generally amended to require a " nominal 40-hour week," meaning that the schedule must average approximately 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> a week.
(c-f) The NRC, through plant technical specifications, requires licensees to maintain records of authorizations for overtime approval. The records ar3 retained by the licensee and, consequently, the NRC does not have the data to answer this question. However, NRC has I periodically evaluated the use of overtime relative to a licensee's plant technical specifications {
and administrative procedures. Consequently, a review of NRC inspection findings concerning i work scheduling and overtime during the past 5 years was used as the princy;el basis for l
answering these questions.
Since 1995,67 inspection reports have documented issues related to working hours and control of overtime at 38 sites. These issues fell into three categories: (1) licensee procedures for shift scheduling or controlling overtime (35 instances), (2) personnel fatigue, either resulting from the number of hsurs worked or changes in shift cycle (53 instances), and (3) frequent use of overtime and cumulative fatigue (38 instances). NRC inspectors found only a few indications of degraded personnel performance related to instances in which significant amounts of overtime had bean worked. However, as noted in the response to Question 3, the staff acknowledges that it is difficult to identify reliably degradations in performance that may result from fatigue and to determine that fatigue is the cause. In those instances that NRC inspectors found indications of fatigued personnel, the instances were of limited safety significance.
NRC inspection reports also indicated an apparently increasing trend in issues documented in inspection reports related to overtime and working hours from 1995 through 1997. However, the 1998 inspection reports showed a significant drop in the number of such issues discussed in the reports. The reason for a drop in the number of findings reported in 1998 is not clear and the data do not provide a sufficient basis for inferring levels or trends in the actual use of overtime.
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E Question 5 For items c) through f) of the previous question, how often did these deviations from NRC guidelines not receive required prior authorization or documentation? For authorized deviations, does the dncumentation demonstrate appropriate and sufficient reason for the deviations, and were the circumstances "very unusual"?
Answer As noted in the response to Question 4, the NRC does not review all overtime approvals for each plant. A review was conducted of NRC inspection rsports for inspections conducted during 1997 and 1998. This review indicated that inspectors documented 67 instances of personnel working in excess of working-hour guidelines without approval and an additional 42 instances in which approval was obtained after the cvertime had been worked. Given that there are 103 operating nuclear reactors, the staff considers these frequencies to be indicative of isolated instances of failure to follow administrative procedures. They do not represent safety-significant issues in the control of overtime.
Of the inspection reports reviewed, few reports explicitly addressed the adequacy of overtime justifications. Only two inspection reports expressed concerns about the adequacy of the
' justifications for the deviations from the overtime guidelines.
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Question 6 How have the staffing levels of safety-related personnel in these plants changed over the past year and past five years? Is there significant variation in the staffing levels at the plants that is not clearly due to differences between the plants?
Answer The NRC does not keep records of staffing levels for all categories of personnel performing safety-related functions at nuclear power plants. However, the NRC maintains records on the number of individuals holding NRC-granted operator licenses. In 1995, there were approximately 4,700 licensed operators working at U.S. commercial nuclear power plants. As of March 1,1999, there were 4,546 licensed operators. Although the total number of licensed operators has declined, there are currently 5 fewer operating nuclear reactor facilities than there were in 1995. As a result, the average number of licensed operators per operating unit has remained at about 42 during this time period. Dual-unit sites, such as the Byron nuclear plant, generally maintain 70 to 90 licensed operators. As of March 1,1999, Byron Station had 93 licensed operators.
The staff is aware that many sites have reduced overall staffing levels in recent years.
However, as noted above, the NRC does not maintain statistics on the number of personnel employed at each site. Consequently, the staff does not have the data to answer this question for all positions considered to perform safety-related functions.
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