ML20245D653

Responds to Re Requested Response to Concerns of H Nickerson Long Work Hrs for Personnel at Various Central Illinois Nuclear Generating Plants.Related Info Encl

ML20245D653
Person / Time
Site:	Dresden, Byron, Braidwood, Quad Cities, Zion, LaSalle, 05000000
Issue date:	09/14/1988
From:	Stello V NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To:	Hastert J HOUSE OF REP.
Shared Package
ML20245D656	List: ML20245D653 ML20245D658 ML20245D661 ML20245D664 ML20246K857
References
CCS, NUDOCS 8809220199
Download: ML20245D653 (2)

Text

-_ _ __

p ( >

UNITED STATES

)

- NUCLEAR REGULATORY COMMISSION

{

g[ wAsmwoTow.o.c.nossa

• • • • • SEP14128

.. 9 The Monorable J. Dennis Hastert United States House of Representatives Washington, D.C. 20515

Dear Congressman Mastert:

I am pleased to respond to your July 21, 1988 letter in which you requested that the Nuclear Regulatory Comission (NRC) respond to the concerns of

' Mr. Moward Nickerson regarding long work hours for the personnel at various

central Illinois nuclear generating plants.

We have been in contact with Mr. Nickerson to determinedifworked he knew information excessively regarding an

.long hoursEnclosure (y activities 1). affected by individuals who haBased on his respo concern is with the practice of overtime in excess of 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> per week.

Odrtime practices are based on a policy statement on plant staff working hours which the NRC issued in 1982. A copy of this policy statement is cnclosed. The policy basis is that enough plant personnel should be employed to maintain adequate shift coverage without routine heavy use of overtime.

Where unforeseen problems or outages require overtime use, the policy limits -

work time to 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> in any 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period, 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 /> period and 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in any 7 day period. Exceeding these limits requires the

' authorization of the plant manager or his deputy or higher levels of manage-went who are charged with considering any reduction in worker effectiveness.

Thus, although Mr. Nickerson expresses a concern regarding 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> shifts, these shifts are permissible as outlined above. This policy was written by the NRC Division of Human Factors Safety.

Subsequent research of industrial and military literature has supported the policy guidelines. A policy statement does not have the legal enforceabliity of a regulation unless a utility makes a voluntary comitment to comply in its license. All. utilities have comitted to complying with the policy statement although some utilities have taken exceptions to parts of the policy.

The three local nuclear plants referred to by Mr. Nickerson are apparently Braidwood Dresden and LaSalle, operated by Commonwealth Edison Company (Ceco).

L Braidwood and LaSalle have license conditions that meet the NRC policy state-l ment for all plant staff. For Dresden, Ceco has comitted to meeting the guidelines of the NRC policy statement in correspondence. However, this

. comitment is not a condition of the license. The Dresden ifcense does reqvf re that procedures be used to control overtime hours for reactor operators.  !

Ceco administrative procedures are used to ensure reactor operator hours of work are controlled in accordance with the policy statement, but those proce-dures are not applied to non-operations personnel such as maintenance, radiological protection and other plant staff. Instead, Ceco relies on amployment icvels which would not routinely require heavy use of overtime.

.The NRC_ hts _.nndgielmeetings with CECO to discuss full implementation of

~ _

MO m Enclosure one

- . T. c .

~

the policy. The most recent meeting was held August 19, 1969, to review obstacles to meeting the policy such as union agreements. The NRC will continue to review Ceco's efforts to resolve this matter.

NRC resident inspectors routinely monitor the overtime at each site aiid the impact of overtime usage. The emphasis is on reactor operator personnel whose attentiveness to plant conditions is observed almost daily and on selected backshifts, weekends and holidays. .The resident inspectors 'also routinely cbserve the performance of maintenance, radiological protection and other plant staff. In addition, the resident inspectors' awareness of plant work loads and their availability to worker complaints keep them attuned to other possible excessive overtime assignments.

Routine resident inspections in this area have been perfomed at Ceco plants and violations ~of policy commitments found. In 1987 for example, the Dresden Power Station was issued a violation for nuclear station operators working hours which exceeded the policy guidelines and for which no management assess-ment had been performed. A followup inspection in 1988 found that Dresden was .

appropriately implementing the overtime policy comitments. In addition to the routine inspections at Braidwood and LaSalle which have not identified any current overtime concerns, we have scheduled a special inspection of the implementation of the overtime control programs at these sites in the next 60: days during which worker overtime hours will be reviewed. Action will be taken as appropriate based on the inspection results.

Sincerely, diginsi signed bg yict4I 3811.8/

'iictor Stello, Jr. .

Executive Director for Operations

Enclosures:

1. Ltr. Weil to Nickerson dated 8/4/88 *

- 2. Ltr. Nickerson to Weil dated 8/8/88

3. NRC Policy Statement .

L l

1

)

.J