ML20211M137
ML20211M137 | |
Person / Time | |
---|---|
Site: | Byron ![]() |
Issue date: | 09/02/1999 |
From: | Dyer J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
To: | Kingsley O COMMONWEALTH EDISON CO. |
Shared Package | |
ML20211M141 | List: |
References | |
50-454-99-11, 50-455-99-11, EA-99-179, NUDOCS 9909090047 | |
Download: ML20211M137 (5) | |
Text
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September 2, 1999 3
EA 99-179 i
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Mr. Oliver D.' Kingsley-j President, Nuclear Generation Group Commonwealth Edison Company i
ATTN: Regulatory Services
~ Executive Towers West lil 1400 Opus Place, Suite 500 Downers Grove,IL 60515 J
SUBJECT:
BYRON OVERTIME AND WORK ENVIRONMENT CONCERNS; INSPECTION REPORT 50-454/99011(DRS); 50-455/99011(DRS)
Dear Mr. Kingsley:
On May 27,1999, the NRC met with Commonwealth Edison Company (Comed) and Byron
' Station management to discuss concerns regarding overtime practices and the conduciveness of the work environment to raising safety concerns at the Byron Sthtion. The NRC acknowledged that the Byron Station safety performance has been good as documented in our -
recent Plant Performance Review (PPR) Report issued on March 26,1999. However, the impact of fatigue on human performance and a work environment that facilitates individuals raising safety concems are critical cross-cutting issues that could affect performance in all safety areas.
. The results of your evaluations and responses pertaining to our requests for additional
- information regarding Byron Station overtime practices and the Byron Station chilled work environment concem were provider) in letters from your staff dated April 30 and May 26,1999, respectively. ~ In addition to the receipt of the letters, we appreciated the efforts of your staff in presenting Comed's viewpoints regarding these issues during the May 27,1999, public meeting held at the NRC Region lli office.
fl Based on a review of the Comed letters and the public meeting presentation, we understand 1
l that Comed has concluded that the use of overtime at Byron Station: (1) was controlled in 1 accordance with the administrative requirements and management expectations established to meet the overtime requirements of the Technical Specifications; (2) did not cross into the realm of rooW0; (3) was not the result of inadequate staffing to support the operational requirements ofthe :ation; and (4) has been controlled in a manner consistent with safe plant operations.
j
- After: viewing the correspondence and public meeting presentation, we are unable to support
( all of your staff's conclusions concerning the appropriate use of overtime at the Byron Station.
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6 9909090047 990902 PDR ADOCK 05000454 a
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e O. Kingsley in particular, your staff concluded that overtime was being controlled in accordance with established management expectations, yet 2.2% of the overtime deviations had been approved
- after the overtime was worked in violation of station procedures. Specifically, Byron Technical
' Specification 6.2.2.e required that administrative procedures be developed and implemented to limit the working hours of facility staff performing safety-related functions. Byron Administrative Procedure (BAP) 100-7, " Overtime Guidelines for Personnel," Revision 11, required prior i approval of guideline deviations. The corrective action taken to address a previous, similar j
violation issued in 1995 reduced the rate of occurrence of these violations but was not fully
' effective to prevent recurrence of "after the fact" overtime approval. Your staff failed to identify 1
the problem through your self-assessment program until prompted by the NRC. This violation has been entered into your corrective action program through Self-Assessment SF-SS-103, Revision 1, dated May 14,1999.
This Severity Level IV violation is being treated as a Non-Cited Violation (NCV), consistent with Appendix C of the NRC Enforcement Policy (50-454/99011-01; 50-455/99011-01). This violation was discussed beween Mr. J. Grobe of my staff and Mr. W. Levis of your staff during a telephone conference call on August 25,1999. If you contest the violation or snerity level of the NCV, you should provide a response within 30 days of the date of this letter, with the basis
' for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001, with copies to the Regional Administrator, Region ill, and the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington DC 20555-0001.
In addition, your staff concluded that overtime usage did not cross into the realm of routine and that staffing has been maintained to support the operational requirements of the station. On average, the Byron Station management approved more than one overtime deviation each day the plant was operating. The deviation approval rate for outage periods approached nine deviations per day. Your staff indicated that the majority of those deviations represented employees working in excess of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in one week. The data supplied by your staff indicated that control room operators worked an average of 7.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> of overtime per week during non-outage times. We believe that the station's overtime practices may not have met the guidelines of Generic Letter (GL) 82-12 as required by Byron Station Technical Specifications with regard to work hours during a normal work week and the frequency of overtime deviations during outages.
The NRC is reassessing the Commission's " Policy on Factors Causing Fatigue of Operating Personnel at Nuclear Reactors" and will be considering alternative regulatory approaches as part of this process, in addition, we acknowiedge your staff's presentation during the July 13,1999, Comed Performance Oversight Panel (CPOP) public meeting in which you committed to take actions to ensure the GL 82-12 work hour guidelines are met at all Comed nuclear power plants and corporate facilities. Based on Comed's commitment, we will not attempt to further evaluate the work hour statistics your staff presented or determine whether other violations occurred regarding the quantity of overtime worked at the Byron Station. We will continue to follow up on safety significant events to determine the root cause, including the potential contribution of personnel fatigue.
O. Kingsley Regarding the chilled work environment concem at the Byron Station, your staff concluded that overall a safety conscious work environment exists and that employees are willing to raise safety concems. However, your staff also concluded that there was a chilled work environment and a need for improvement in the operations department. During the May 27,1999, public meeting, your staff stated that there had been significant management personnel changes at the Byron Station and the new management team was committed to maintaining a work environment conducive to the raising of nuclear safety issues. Finally, your staff stated that Comed planned to perform an additional assessment of the safety conscious work environment in the near future.
We reviewed the information presented during the public meeting and your letter dated May 26,1999, responding to specific questions the NRC posed about the chilled environment concem. The NRC concluded that your self assessment of the Byron Station work environment could have been more effective by using different methods of gathering data. Notwithstanding, i
the NRC agrees with the results of your investigation that a substantial majority of the Byron Station work force was willing to raise concems. However, a chilling effect by its nature can exist and detract from a safety conscious work environment because of personal perceptions of retribution for raising safety concems. Management actions, intentional or not, can influence an individual's perception. We agree that there was a chilled environment within the operations department that was not conducive to a safety conscious work environment. Your staff has taken actions to improve the work environment in the operations department. In addition, your staff has also taken actions to correct misconceptions conceming problem identification forms and NRC/lllinois Department of Nuclear Safety contact forms. These activities should contribute to an improved work environment at the station.
In summary, we conclude that your staff violated NRC requirement 3 concerning overtime deviation approval. We encourage your continued efforts and commitment to control the use of overtime. We believe that a chilled environment existed in the operations department and acknowledge your actions te enhance that work environment. We appreciate your commitment to perform a follow-up self-assessment of the safety conscious work environment and request that you submit to NRC Region 111 the results of that assessment and any further actions. We recognize that your actions to address problems with overtime control and to ensure a safety conscious work environment are in process and we will continue to evaluate your progress in these areas.
Enclosed with this letter is a letter from the Union of Concemed Scientists (Enclosure 1) that provided comments on the May 27,1999, public meeting, and a letter from a concerned individual (Enclosure 2) concerning the validity of the investigation conducted by the Comed Nuclear Oversight Organization. These letters are enclosed as they address similar concerns the NRC has addressed in this letter. They are provided for information only. Also enclosed with this letter is a copy of your staff's slides that were presented during the public meeting (Enclosure 3). An inspection report number has been assigned to this letter only for NRC tracking purposes; an inspection report is not enclosed. We appreciate your cooperation and will gladly discuss any questions you may have concerning this information.
E 1-
- O.' Kingsley -
l If you have any questions regarding these issues, please feel free to contact Mr. John Grobe, Director, Division of Reactor Safety, at (630) 829-9700. In accordance with 10 L
CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter and your response will be placed in the NRC Public Document Room.
Sincerely,.
Original /s/ J. E. Dyer J. E. Dyer Regional Administrator Docket Nos. 50-454; 50-455 License Nos. NPF-37; NPF-66 l
Enclosure.:
As stated cc w/encis:-
D. Helwig, Senior Vice President, Nuclear Services C. Crane, Senior Vice President, Nuclear Operations -
H. Stanley, Vice President, Nuclear Operations R.' Krich, Vice President, Regulatory Services DCD - Licensing
- W. Levis, Site Vice President
- R. Lopriore, Station Manager B. Adams, Regulatory Assurance Manager l
- M. Aguilar, Assistant Attomey General State Liaison Officer State Liaison Officer, State of Wisconsin Chairman, lilinois Commerce Commission L
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Distribution:
R. Borchardt, OE w/encls D. Dambly, OGC w/encls V. Odaz, NRR w/encls COT (E-Mail) i RPC (E-Mail)
GFD (Project Mgr.) (E-Mail)
J. Caldwell, Rlli w/encls B. Clayton, Rlli w/encls l
SRI Byron w/encls DRP w/encls -
DRS w/encls Rlli PRR w/encls PUBLIC IE-4fw/encls Docket File w/encls GREENS IEO (E-Mail)
DOCDESK (E-Mail)
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