ML20236G160

Confirms 870930 Conversation Between Util & NRC Re Overtime Controls at Plant.Results of Evaluation Requested within 20 Days of Date of Ltr

ML20236G160
Person / Time
Site:	Pilgrim
Issue date:	10/08/1987
From:	Kane W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Bird R BOSTON EDISON CO.
Shared Package
ML20236G149	List: ML20236G146 ML20236G160
References
NUDOCS 8711020442
Download: ML20236G160 (2)

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ENCLOSURE I Page 1 of 2 Pages i

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'o UNITED STATES

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!" <> NUCLEAR REGULATORY COMMISSION I REGION i l i ,I S31 PARK AVENUE j

/ KING OP PRUSSIA, PENN$YLVANIA 19408 OCT 081987 l Docket No. 50-293 Boston Edison Company ATTN: Ralph G. Bird Senior Vice President - Nuclear 800 Boylston Street Boston, Massachusetts 02199

Dear Mr. Bird:

30, 1987 conversation between confirms the September f This letter the Mr. Samuel Collins of my staf f and you' regarding overtime controls at l Pilgrim Nuclear Power Station. During that conversation, you indicated that '

you had received a letter alleging excessive overtime Further, youand thatto agreed you were also evaluate the aware of similar allegations in the press.

situation to determine whether overtime controls at the site are being effec-tively implemented for all personnel including: (1) whether instances of over-time in excess of NRC guidelines are being reviewed and approved as required; of overtime actually approved and the attendant and, (2) whetter the amount of NRC guidance on controlling circumstances You is consistent with the intent indicated that you would provide a written report to NRC working hours. be provided within 20 days of the date of ,

Region I. We request this report this letter.

will be of assistance to NRC Region I in The above described evaluation reviewing this matter. If your understanding of this agreement differs f rom that described herein, please contact this office promptly.

Thank you for your cooperation in this matter.

Sincerely, Wi liam F. Kane, Director Division of Reactor Projects fbk DR P

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• ' ENCLOSURE 1 Page 2 of 2 Pages i.

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Boston Edison Company OCT H 1987 i,

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'cc:

K. P. Roberts, Nuclear Operations Manager Pavi levy, Chairman, Department of Public Utilities Chairman, Board of Selectmen Plymouth Civil'0efense DirectorJ. D. Keyes, Boston Edison Regulatory Af E. D. Robinson, Nuclear Information Manager R. N. Swanson, Nuclear Engineering' Department Manager The Honorable E. J. Markey Senator Edward P. Kirby-

'The Honorable Peter V. Forman '

Sharon Pollard, Secretary of Energy Resources Peter W. Agnes, Assistant Secretary of Public. Safety, l

Commonwealth of Massachusetts Rachel Shimshak, MASSPIRG l

'Public DocumentRoom Local Public.0ccument Room (POR) (LPDR) . ,

Nuclear Safety Information Center (NSIC)

NRC Resident Inspector Commonwealth.of Massachusetts (2)

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ENCLOSURE 2 L,' -

Page 1 of 6 Pages MASSPIRG 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 1 assurance, instrumentation and control, radiological health and safety, operations and plant maintenance....results in poor workmanship and a 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, j I would appreciate a rerponse to this request within 30 days.

Thank you for your consideration of this important matter.

Sincerely, ,

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Rachel Shimshak Energy Advocate Enc. . l $_ _

JAU p D

cc: Regional Administrator Region I j U.S. NRC i 631 Pa rk Ave.

King of Prussia , PA 19406 29 Temple Place, Boston, MA 02111 (617) 292-4800 ***"

ENCLOSURE 2

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There is a critical problem at the Pilgrim Nuclear Power I 1

Station in Plymouth that needs to be addressed, and it is my 1

hope that after reading this, you will do so in your official capacity. It is a hidden problem, and as potential victims of its consequences, you' and I must bring it out in the open and force i! resolution.

I am employed at pilgrim in a management capacity. I have seen the station evolve over the past 10 years in terms  !

l of upgraded sys tems and equipment , new procedures, and a manage-ment committment to an improved physical working environment. l I- have always considered myself a fervent supporter of the nu-clear industry as a viable interim energy alternative as well as

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

Technology notwi thstanding, I have come tc see clearly why the criticism levied towards Bos ton Edison managemen t during the past J '",, y e a r s becomes poignant and indefensible. Examina t i or, of nuclear events in recent histcry undeniably demonstrates their root cause to ;_e no with equipment failure or malfu.ction but from poor hurur Judgement or decision.

pi ,mWiv it .i r

,9 mana.qement cf a r.uclear facil;ty

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ula t o r s that mi c

t r.i<:ld r the I re: P 1 re urin t' 'i .s c.11 t y an ; r -. . : m ci t. h e i peruun: .

.ing and maintaining our nuclear plants. l Ma amount o f nuclear grade material, revised and error- i

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free procedures, or rigorous qual ity assurance standardc :m l i

SubDt!' ' '.t i : J ,I , ci ). '. ,

and t e atr. - c r i e n '; e ,i pers?nnel, l t i

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'S-3C-37 l

l Around 1980, the Nuclear Regulatory Commission issuei a L

l ' Federal Regulatory Guide for nuclear power plants. Though not j prescribed by law (yet strongly encouraged by the NRC) the guide  !

I linked events or near events at this country's nuclear power plan ta wi th the excessive amoun t of overtime required of workers  !

at the plan t. The guide stron5 1 y suggested the minimization l of personnel overtime, notto exceed 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> per week and '

six consecutive days.

Several years ago Boston Edison management was severely

. criticized for understaffing and for its wholesale use of over-time. Implicit in this criticism was the suggestion that over- l worked and fatigued personnel contributed largely to the facil-ity 's poor oafe ty record.  !

3! t. b o beginning of the current refueling and maintenance outagu, wutdate was issued by plan t management res tricting the use o f overtime to conform with t he spirit of the aforementi:ned l I

regulatory guide.

The intent, however nobly directed, was quickly re;1 ace; with management's commitment not towards safe " an_ pal _ 7, bu:

towarda the economic and political momentum of placing a mi_lian-

. and-a-half dollar per day elec trical generator cr. line as sc:a as possible. n fe ty concerns, work quali ty and t h t: : case :er humnn toll were soon replaced wi th the term, " critic 11 ;a:n,"

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that is, work whjch most impac ted unit startup. : nit ally wrere ]

i tight administrative controls had been placed uper the use cf overtime, the priority became and remains the need to get the job done at wha tev er cos t 0: reuulL. "'arte b ia: _ _ ;._ __ i

ENCLOSURE 2  !

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Page 4 of 6 Pages l

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of overtime is well documented in two, four-inch thick volumes I 1

maintained by the utilly's outage management group. .

Despite their size, these volumes represent overtime use only since the l d

be61nning of 1987. l 1

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 i

for months on end. Consider that many of the workers have been 1

-involved in an' outage that- has been ongoing for a year or more, i

It is reasonable to suggest that those people responsible for the l public health and safety have been required to push themselves I well beyond the limits of good judgement, and all at the direction )

l of plant management. Consider, too, the implications of working J the equivalent of a week and a half to two weeks in a single week, and under the extraordinarily stressful conditions of working in n no 6. r plant and a zero defects environment.

Those personnel responsible for quality assurance, instru-I menta tion and c on trol, radiological health and safety, operations and plant maintenance routinely exceed MRC guidelines on overtime.

The result is poor workmanship and a consequent comprcmise in safety.

My recen t conversations w.i th those associated witr the local ,

I medical conmuna ty bear out the adverse effects o f excess;ve aver- j time, , .n Wa, to2a : onf1' nt; ally tl J F r . :r i_. -  ;. . ; -

centage of tilgrim S tation workere suffer from fatigue , depre a n ce and' work-related utreuu. These represent the very came worker 5 responu]blc for the maintenance and safe operation of the station.

'l need to emphasize that I am neither angry acr v.n n _.-

but concerned, damned concerned. I believe in our industry ..

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ENCLOSURE 2

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Page 5 of 6 Pages 8-30-87

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i I beljeve in what I do for a livinn. Many positive strides have been made by Boston Edison with respect. to the mo'dernization of our plant. I am saddened,.however, that the company has yet to respond positively to its greatest criticism and challenge: the ability to effectively manage.

le a plant originally designed to operate with 250 people, and in an era where major outages in similar facilitics typically require 500 to 600 additional people, why does the Pilgrim site currently have a staff of over 3400? Why must Boston Edison management push its human resourcea to the threshbld 'of error and beyond?

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

You, too, may have reason to be concerned.

Please do no t treat this at, just another anonymous com-plaint. I must remain anonymous because I sincerely fear for my job, which I like v ery much , and my 11fe. I have included in this.}etter an objective resource for you to check to verify toe in formation I have nupplied.

V e ry :ba r tly J will have an anonymous in termediary contac t you to whom yen may address y our ques tions. The in termediary 1

will subsequently bring those quest. ions to me, and I will answer

• hem nd send them back to y ou .

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< -ENCLOSURE 2

,- Page 6-of 6 Pages 8-30-87 cc: Boston Globe l Th e . }{erald I

l: , The ' Enterprise .-

i Patriot Ledger l

' Old colony Memorial Department of Labor Nuclear Regulatory Commission

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