ML20235K869

Requests Investigation of Severe Overtime Problems at Facility.Encl Ltr Shows That Overtime Results in Compromise of Safety.Response Requested within 30 Days

ML20235K869
Person / Time
Site:	Pilgrim
Issue date:	09/30/1987
From:	Shimshak R MASSACHUSETTS PUBLIC INTEREST RESEARCH GROUP
To:	Murley T Office of Nuclear Reactor Regulation
References
NUDOCS 8710050260
Download: ML20235K869 (6)

Text

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i MASPIRG MASSACHUSETTS PUBLIC INTEREST RESEARCH GROUP September 30, 1987 Dr. Thomas Murley Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Dear Dr. Murley:

I am writing to urge you to investigate severe overtime problems at the Pilgrim nuclear facility in Plymouth, MA. Previous SALP reports have made mention of the excessive use of overtime at the plant, and recent accounts underscore the same problem.

Within the last two weeks, I have received several calls from employees at the plant and/or their spouses expressing grave concern about the health of workers and the safety of the plant due to overtime. Unlike the company's statements that overtime is under control, these workers explain that " plant workers routinely work 72 and 84 hours9.722222e-4 days <br />0.0233 hours <br />1.388889e-4 weeks <br />3.1962e-5 months <br /> per week for months on end." The enclosed letter shows that overtime of " personnel responsible for quality assurance, instrumentation and control, radiological health and safety, operations and plant maintenance. .. .results in poor workmanship and a i consequent compromise in safety."

The Peach Bottom experience should bear a lesson on good mangement and the use of overtime. This and other continuing management, structural and emergency planning issues make the plant unsafe.

It is with great concern about the health and safety of Pilgrim workers and citizens of the state of Massachusetts that I ask you to promptly investigate this matter and keep the Pilgrim plant closed until it can be proven that this issue and others have been completely resolved. I would also ask that you obtain a copy of the overtime documentation being kept by the outage management group at the Pilgrim plant.

I would appreciate a response to this request within 30 days.

Thank you for your consideration of this important matter.

Sincerely, _.

8710050260 8709 L h i j a / ' k' g .g d4k PDR P

ADOCK 050 Q PDR Rachel Shimshak Energy Advocate Enc.

cc: Regional Administrator Region I U.S. NRC \ p 631 Park Ave. t King of Prussia , PA 19406 29 Temple Place, Boston, MA 02111 (617) 292-4800

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8-30-87 L .-There is a critical problem at the Pilgrim Nuclear Power l

Station in /Flymouth that .needs to be' addressed, and it is my h' ope ;that after reading this, you will do so in your official ,

capacity.- ItEis'.a hidden. problem, and as potential victime of-its- consequences, you ' and I must bring it out in the open and force i' t'es oluti on .

-1 am employed at Pilgrim in a management capacity. I have seen. the station evolve over the past 10 years in terms 1'

-of' upgraded systems and equipment, new procedures, and a. manage-ment committment to an improved physical working environment. l 1

I have always considered myself a fervent supporter of the nu-clear industry as a viable interim energy alternative as well as  ;

a supporter of the technology that forms the basis for the safe n' and reliable operation of Pilgrim Station.

Technology notwithstanding, I have come to see clearly why the criticism levied towards Boston Edison management during the past few years becomes poignant.and indefensible. Examination of nuclear events in recent history undeniably demonstrates their root cause to lie not with equipment failure or malfunction but t

from poor human judgement or decision.

Ultimately it is the management of a nuclear facility

-in communion with our public regulators that must shoulder the  !

resimusj i' li ty for ensuring the quality and readiness of the personnoi n;'et'alind and maintaining our nuclear plants.

No amount of nuclear grade material, revised and error-free proceduren, or r16orous quality assurance standards can subst.1tw -

l'c . .m i l trained, alert, and team-oriented personnel.

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-Around 1980, the Nuclear Regulatory Commission issued a Federal Regulatory Guide for nuclear power plants.- Though not prescribed by law-(yet strongly encouraged by the NRC) the guide L linkdd events or'near events at this country's nuclear power plan td wi th . the ' excessive; amoun t . of overtime required .of workers

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The guide strongly suggested the minimization

' of personnel overtime, not'.to exceed 60 hoabs 'per week and et"

.six. consecutive days.

Several years. ago Boston Edison -management was severely ,

1 criticized for understaffing and for its wholesale use of over-time. Implicit in this criticism was the suggestion that over-worked and fatigued personnel contributed largely to the facil-

.ity 's poor narc ty record.

Al. .the begJnning of the current refueling and maintenance outagu, n andate was issued by plant management restricting the use of overtime to conform with the spirit of the aforementioned i regulatory- guide.

l-L The intent , however nobly directed, was quickly replaced with management's commitment not towards safety and quality, but l

[ towards the economic and political momentum of placing a million-l and-aihalf dollar per day electrical generator on line as soon

- as possible. Safety concerns, work quality and the ccusequent human toll were soon replaced with the term, " critical path,"

that is, work which most impacted unit startup. Initially where 3 tight administrative controls had been placed upon the use of overtime, the priority became and remains the need to get the j job done at whatever cost or resu3L. " Carte blanche" approvC l_---__-___--______-__

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6 'of-overtimeLis'well documented in two,-four-inch thick' volumes L' maintained. by ; the r utiliy s . outage management : group. - Despite,

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their' size,! these . volumes represpnt overtime use only _ since the.

L beginning of.1987.

Plant -wmers routinely work 72 and 84. hours'per week for' months.on end. Consider that many of the workers have been i

. involved in an outage that han 'been ongoing for a year or more, i It'is reasonable:to suggest that those people responsible for the -

public' health and safety.have been required to push themselves 1

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well-:beyond the limits'of' good judgement, and all at the direction L of nlant management. Consider, too, the implications of working 1

. the - equivalen L of a week and. a half 'to two weeks in a . single j

i week, andLunder the extraordinarily' stressful conditions of working'

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in_a pu t ror plant and a zero defects environment.

i Those personnel responsible for quality assurance, instru-- U mentation and control, radiological health and safety, operations 1

and plant maintenance routinely exceed NRC guidelines on overtime. l The result is poor workmanship and a consequent compromise in safety.

My recent conversations with those associated with the local medical communa ty bear out the adverse effects of excessive over- l time. ] have been told confidentially that an inordinate per-centage of Pilgrim Station workers suffer from fatigue, depression and work-related stress. These represent the very same workers responsib]e for the maintenance and safe operation of the station.

I need to emphasize that I am neither angry nor vindictive but concerned, damned concerned. I believe in our industry and

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.I bel.ieve in what I do for a living. Many positive strides have beemadeLby n Boston Edison with respect to the modernization of our' plant. . I' am saddened, however, that 'the company has 'yet to respond positively to'its greatest criticism and challenge: the ability . to e ffeetively manage.

le a plant originally designed to operate with 250 people, and in an era where major outages in similar facilities typically require 500 to 600 additional people, why does the Pilgr.im site currently have a staff of over 3400?. Why must Boston Edison management push its human resourcoa.to the threshold'of error-l and beyond?  !

In view of all the criticism focused on plant management in the past, is this the mark of prudent and enlightened manage-ment?

i You, too, may have reason to be concerned. t Please do not treat this as just another anonymous com-plaint. I must remain anonymous because I sincerely fear for my job, which I like very much, and my life. I have included in this letter an objective resource for you to check to verify the i n forma t i on T have nu pplied.

Very shortly I will have an anonymous intermediary contact 1

you to whom you may address your questions. The intermediary will subsequently bring those questions to me, and I will answer them and send them back to you.

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8-30-87

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Patriot Ledger Old' Colony Memorial Department of Labor Nuclear . Regulatory Commission m

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