ML20207B897

Expresses Concern That Low Staffing Levels & Excessive Staff Overtime May Present Serious Safety Hazard at Some Commercial Nuclear Plants in Us

ML20207B897
Person / Time
Site:	Byron
Issue date:	02/25/1999
From:	Dingell J, Klink R, Markey E HOUSE OF REP.
To:	Shirley Ann Jackson, The Chairman NRC COMMISSION (OCM)
Shared Package
ML20207B880	List: ML20207B875 ML20207B897
References
IEIN-91-036, IEIN-91-36, NUDOCS 9906020146
Download: ML20207B897 (3)

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February 25,1999 4

Shirley _ Ann Jackson 3 Chairman l Nuclear. Regulatory Commission l' Wa's hington, DC 20555

Dear Ms. Jackson:

We are writing in concem that low staffing levels and excessive staff overtime may present a ,

serious safety hazard at some commercial nuclear plants in the United States. The Nuclear l Regulatory Commission (NRC) Information Notice 91-36 expressed the potential problem well: f The safety of nuclear power plant operations and the assurance of general public health and safety depend on personnel performing theirjobs at adequate levels.

I Research on extended working hours indicates that the performance ofindividuals will degrade without adequate rest after long periods of work. Fatigue.can l i

. degrade an operator's ability to rapidly process complex information such as that presented by off normal plant conditions. In addition, fatigue may jeopardize the ability to mpond in a timely fashich. Furthermore, performance errors are more

'likely to occur as a result oflapses in short-tenn memory.

We have recently heard reports of routine use of staff overtime at nu: lear plants that, although a'uthorized, appears likely to exceed the " temporary basis" and "very unusual circumstances" standards for overtime (as described below). Such concems at one plant recently were described in the article " Byron operators complain too much overtime could jeopardize safety" in the February 15,1999 issue ofInside N.R.C. In addition, we are concerned that indatry cost-cutting in response to the emerging competitive electricity market could be leading to staffreductions that will exacerbate overtime problems and degrade the ability to safely handle plant emergencies. .

The need to control s'aff t working hours has been recognized at least since the review of l

l nuclear plant safety following the accident at Three Mile Island twenty years ago, with IE l

Circular No. 80-02 and the TMI Action Plan (NUREG-0737 Item I.A.I.3). The new policy was stated in 1982 in Generic Letter 82-12: "Enough plant operating personnel should be employed to maintain adequate shift coverage without routine heavy use of overtime. The objective is to have operating personnel work a normal 8-hour day,40-hour week while the plant is operating."

The letter did accept use of overtime for safety-related personnel"on a temporary basis" under specific guidelines, including, "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, nor more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in any 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> pertpd, noQnore than 72 N

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2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in any seven day period." Deviation from these guidelines in "very unusual circumstances

... shall be authorized by the plant manager or his deputy, or higher levels of management" and "shall be documented and available for NRC review." However, Generic Letters are not

• enforceable, and InformationNotlee No. 91-36 noted several instances in 1989 91 of excessive use of staff overtime, staff fatigue, and inadequate authorization and documentation for ' overtime.

Information Notice 91-77 documents related problems with insufficient shift staffing during plant emergencies.

Although it is very difficult to determine if specific examples of operator error are caused by fatigue, we believe that staffing and overtime are serious safety issues, and have concerns both about specific plant practices and about current NRC regulations. Thus we respectfully request that the NRC investigate the prevalence oflicensee staff overtime and its safety significance. In ,

particular, we would appreciate your assistance in answering the following questions:

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 i for airline pilots and truck drivers?

2. What definitions or standards for " routine heavy use," " temporary basis," and "very unusual circumstances" does the NRC use in evaluating plants' cvertime usage?

3. 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?

4. For all nuclearplants in the U.S. over the past year, with what frequency did safety-related personnel a) work more than eight hours a day (while the plant was operating), b) work more than forty hours 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 /> 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 more 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 ofless than eighthours?

5. For items c) through f) of the previous question, how often did these deviations from NRC guidelines not receive required prior F 'horwtion or documentation? For authorized deviations, does the documentation demonstrate appropriate and sufficient reason for the deviations, and were the circumstances "very unusual"?

6. How have the staffing levels of safety-related personnel in these plants changed over the past year and pasc five years? Is there significant variation in the staffing levels at the plants that is not clearly due to differences between the plants?

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3 Thankyou for your assistance. Ifyou have questions concerning this letter please feel free to contact Mr. Lowell Ungar or Mr. Jeffrey Duncan on the ::taff of Congressman Markey at (202)225-2836, t Sincere!y, fA. ,_1 k. _

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l John D. Dingell l x

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