ML20245D661

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Submits Listed Comments in Response to Re Safety Practice to Schedule Nuclear Plant Operating & Maint Personnel for 16 H Shifts &/Or Excessive Overtime
ML20245D661
Person / Time
Site: Dresden, Byron, Braidwood, Quad Cities, Zion, LaSalle, 05000000
Issue date: 08/08/1988
From:
AFFILIATION NOT ASSIGNED
To: Weil C
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
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ML20245D656 List:
References
NUDOCS 8809220211
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  • / August 8,~1988

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l erares of parties and certain other Ident! 'ylop

(' detalls have been renoved In order to prevent-p a clearly unwarranted Invaston of the pernon:,1 p'r!vacy of the Individuals Involved.

United States Nuclear 3 Regulatory Commission R:gion 111' 799 Roosevelt Road - Box 2027 i '

iGlen Ellen, IL 60137 ATTNs Charles B. Weil, 2nvestigatien and Compliance specialist In reply to your. letter of August 4, 1988,.I have the following comments.

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The effect that sixteen hour shifts hno on nuclear plant operations in the past is not the issue. and/or excessive My ove Is it a safe practice to schedule nuclear question'was as follows. 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> shifts and/or

-plant? operating.and maintenance personnel for 1In view of the millions

-oxcessive en plant overtime.

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compliance inspections, it is my opinion that some consid ation should be given to the number of hours plant personnel work.

reaction time I,oss of'or inadequate sleep effects judgement, Frequently people working and the decision making process.

chifts reduce their hours of sleep in order to meet the demands for f their time by their employer, the family, civic and l social have respona.t-difficulty bilities. . To compound these problems many peop e adapting to a constantly changing' sleep schedule dictated by rot chift assignment.

It is.my. opinion that nuclear plant operating and maintenance personnel should not be scheduled for more Further, there shouldthan eight hours pe be sixteen and' forty-eight hours per week.

hours between shift changes.

I am aware that nuclear generating plants are controlled h tby man total automatic fail safe systems and have every safe guard t a can design. However, operators are essigned to assure the systemsIf th operate within prescribed limits. l t the operator must have the knowledge, the judgement and the a e ,

to respond to the emergency.the wrong decision if he has not had adequa as a supervisor--manager I know from first ofhand oil experience and coal thatfired Na l

steam generating plants.

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Other demands ceployees on rotating shif ts have' problems sleeping.for their time problem. I have actually seen people fall asleep while standing up.

' e: emes of parties and certeln $ ot er Identifyin,

[ details have been removed In order to prevent a clearly unwarranted invasion of the persc.n.i arivacy of the tedivid.ints Inve,1ved.

CC: Congressman S. Dennis Hastert CLN/jsh 4

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MF.NTS '

-b POlt Y POLIC estended pededs of abundown for parannount eeneidereUonin such erfve ' .mejor mehenense or me)st setborissues.abaB be bt significant plant medincetiens;and p)1be sedocuensla e eDecuveness of oddition of a phrase e Was operatirepemennd wedd be highly estended obvidownpad freesthe

-is to eonside,ese erover.me enlaeL.

in . dwes ore sa anIndividualbeels. encewaged

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. IAcensus of opereung plants and board delag theh tour of duty.

ePPlicants for operating beenses abal con swatnem seronmation oosriaen '

establish eestrols to pmvent elinesens 34r.84wasee P.Creder.(ars)mst* '

where fatigue sodd moose 6e obtuty of opersuas personnet te keep the master ,ggMeMWM eine asth der

    • ' ** *' Jer the N dear Reguletary Cesenteessa.

bin and 6e m pahaA.Ewebend. .

everthne-4ey Jobes ted fossere est Anflance fougue.

The objeceve of 6e sostrels would be Q#*/g A"" 8#

N M*m eum5seriene areasA to assure that,to the estaat practiesble, personnet are not as to sbh J dunes wb!!eina fa e 1 eould algutScancy ese elrmental

.sadison .et siertosas er b!r decislas ,

sepabnity.The sentrois abaB to

. the plant star who perform selsted funcuens (eg, eenler sessaar operetern, peactor operstars, health peysicista,suaR!ary yters,and boy maintenance

- iasperseasel Enoaghpirat operst should be e,mployed to malatela edequele shlrt coverage without restine benvy use of evertime.h objective is tohave operating personne! mark e ocma! shut day.eboer wed w%.e the plantis operating.However.in event that maioreseen problems petelre e F3 SeeN

      • smsus em substan6a! amounts of evertime to'be osed er dwing extendedperlede of stueleer Powerplant Statt Wertuis g'

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- modma. - en.te u.e foBowing guidelines ebaB be messetMedser Regulatory a.AnInd cour.;iselas. r,.e.ied ividualobould wo,t om - met.be

.os,e.c ,,bbm.o. ef,evi e,,on.,

seder power plant stag str gcg! g time).

,a,mi,ied t. wo,b more .a. - -

. 0e rei,r.ar, .. .e .n, -bw ,e,io& so, mere .a. .

bours in any #-bow peded mer mese

- pludearRegelseoryComtalasles thaa 72 bows in any sevenday persed pub 1thed a"Pulicy on Facters Censlag (aB enduding ab!ft hrmover ums).

. Fattrue of Opentirig Personnelat s. Abrea of atkast eightbeare Divelear Russes.* 4F FR Fast. should be aDowed between week Comments puerived sinos pub 11ce5em periods (indeding abih turnover thme).

l beve revealed yestions eencerning te d.Except during extended abstdown petity statement Accordingly.the Periods,the nas of overties should be

' gober etateness has been avised and seasidemd on anledividualbasis and G,e resteed werden is reproduced belour. mot for the entre star en a eht, )

OdgesIndmec(11m addidea.of a Recognidagthatvery onesed sentaner whldespUcitly states st &s edicumstances may arine .

e of ne workirq bow policyis devia6an from the above to operogma'personnelwork an 8 such deviation abat be a by how day.e6&ser weele (t)N addissa, the plant manager er his .or ofa se to bdicate that the statgg beer sustrictier.: are applicable higbar hvels or maangement.

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NUCLEAR RECULATORY COMMISSION

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! Docket'No. 50-456;'50-457, 50-454; 50-455, 50-237; 50-249, 50-373; 50-374,.

'50-254; 50-265, 50-295; 50-304 Commonwealth Edison Company ATTN: 'Mr. Cordell Reed

. Senior Vice President Post Office Box 767 Chicago, IL 60690 Gentlemen:

This refers to'the routine safety inspection conducted by Messrs. R. Lerch -

and M. Kunowski of this office from August 16, 1988 to August 2, 1989, of.

activities at the Braidwood, Byron, Dresden, LaSalle, Quad Cities and Zion Nuclear Power Station.-authorized by NRC Operating Licenses No. NPT-72, ho. NPF-77; No. NPF-37, No. NPF-66, No. NPF-19 No. NPF-25; No. NPF-11,

^ No. NPF-18; No. NPF-29, No. NPF-30; No. NPF-39..No. NPF-48, and to the discussion of our findings by telephone with T. Kovach and others of your

. staff-at the conclusion of the inspection.

The enclosed copy of our inspection report identifies areas examined during the inspection. Within these areas. the inspection consisted of a selective examination of procedures and representative records, observations, and

- interviews with personnel.

As a result of this inspection, we are concerned that you do not appear to have sufficient measures in place to' ensure that safety-related work is not being jeopardized by personnel having worked too many hours. In this regard we request that you respond to the concerns identified in Section 4 of this report within 60 days and include'in this response the measures that Commonwealth. Edison has taken or plans to take to ensure consistent application of the overtime requirements at all Commonwealth Edison Nuclear Stations.

'No violations of NRC requirements or deviations from comitments were identified during the course of this inspection.

In accordance with 10 CFR 2.790 of the Comission's regulations, a copy of this letter, the enclosed inspection report and your response will be placed in the NRC Public Document Room.

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Enclosure Two

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. Consnonwealth Edison Company 2.g 4 gg We will gladly discuss any questions you have concerning this inspection.

I Sincerely, .

)3abc LMw Edward G. Greenman, Dirdefor Division of Reactor Projects

Enclosure:

Inspection Reports No. 50-456/88024(DRP); 50-457/88024(DRP)

No. 50-454/88015(DRP); 50-455/88014(DRP)

.No. 50-237/88020(DRP);L50-249/88021(DRP)

No. 50-373/88023(DRP); 50-374/88022(DRP)

No. 50-254/88022(DRP); 50-265/88022(DRP) ~

No. 50-295/88017(DRP); 50-304/88017(DRP) cc w/ enclosure:

.T. J. Maiman, Vice President, PWR Operations T. Kovach, Nuclear Licensing Administrator T. Joyce.. Station Manager, Zion R. E. Querio, Station Manager, Braidwood D. E. Cooper, Regulatory Assurance Supervisor J. Eenigenburg, Plant Manager Dresden -

G. J. Diederich Station Manager, LaSalle R. L'. Bax, Plant Manager Quad Cities R. Pleniewiecz, Station Manager, Byron DCD/DCB (RIDS)

Licensing Fee Management Branch Resident Inspector, RIII Braidwood Resident Inspector, RIII Byron Resident Inspector, RIII Dresden Resident Inspector, RIII LaSalle Resident Inspector, RIII Quad Cities Resident Inspector, RIII Zion D. W. Cassel, Jr., Esq.

~ Richard Hubbard J. W. McCaffrey, Chief, Public Utilities Division Diane Chavez, DAARE/ SAFE H. S. Taylor, Quality Assurance Division David Rosenblatt, Governor's Office of Consumer Services Mayor, City of Zion E. Chan, DGC G. Berry, OGC Stephen P. Sands, NRR L. 01shan, NRR, M C. Well, RIII

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4 U.S. NUCLEAR REGULATORY COMMISSION REGION III

^ 7 Report Nos. 50-456/88024(DRP); 50-457/88024(DRP) 50-454/88015(DRP); 50-455/88014(DRP) .

50-237/88020(DRP); 50-249/88021(DRP) 50-373/88023(DRP); 50-374/88022(DRP) 50-254/88022(DRP); 50-265/88022(DRP) 50-295/88017(DRP); 50-304/88017(DRP)

Docket Nos. 50-456; 50-457 License Nos. NPF-72; NPF-77 50-454; 50-455' NPF-37; NPF 50-237; 50-249 DPR-19; DPR-25

' 50-373; 50-374 NPF-11; NPF-18 50-254; 50-265 DPR-29; DPR-30 50-295; 50-304 DPR-39; DPR-48 Licensee: Commonwealth Edison Company Post Office Box-767 Chicago,'IL 60690 Facility Name: Braidwood Nuclear Power Station, Units 1 and 2 Byron Nuclear Power Station Units 1 and 2 Dresden Nuclear Generating Station, Units 2 and 3 LaSalle. County Station Units 1 and 2 Quad Cities Nuclear Generating Station, Units 1 and 2 Zion Nuclear Power Station, Units 1 and 2 Inspection At: Region III, Glen Ellyn, Illinois Inspection Conducted: August 16, 1988 to August 2, 1989 Inspectors: R. Lerch M. Kunowski Approved By: D Shafer fef Reactor Projects Branch 1 late e

Inspection Sunnary

-Inspection from August 16, 1988 to August 2. 1989 (Report Nos.

50-45b/88024IDRP); 50-457/88024(DRP) 50-454/88015(DRP); 50-455/88014(DRP) ;

50-237/88020LDRP); 50-249/88021(DRP) 50-373/68023(DRP); 50-374/88022(DRPJ; 50-254/88022LDRP); 50-265/88022(DRP) 50-295/88017(DRP); 50-304/88017(DRPJ Special unannounced inspection by region-based inspectors of Areas Inspected:

procedures and data regarding control of overtime in accordance with the NRC Policy Statement " Nuclear Power Plant Staff Working Hours" and an allegation.

Results: No violations or deviations were identified; however, several concerns were forwarded to the licensee for response.

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DETAILS

1. Persons Contacted Commonwealth Edison Company (Ceco) -.
  • John F. Gudac, Corporate Ma'intenance Superintendent
  • Frank Rescek, Assistant Radiation Protection Director

'*Neil P. Smith, BWR_ Licensing Supervisor

  • Gerald L. DeYoung.-BWR Licensing Engineer

+* Richard Flessner, PWR Operations

+ Thomas Kovach, Nuclear Licensing Manager

+ Steven'Hunsader. Nuclear Licensing Administrator

+ Charles Sargent, Administrative Engineer

  • Denotes those. attending the working meeting conducted on August 19, j 1988, and at other times throughout the inspection period.

+ Denotes those contacted by telephone call on August 2, 1989.

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2. Details

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This inspection was conducted to. determine the overtime practices at <

each of the licensee's nuclear sites and whether they meet the " Policy on Factors Causing Fatigue of Operating Personnel at Nuclear Reactors" which was issued in Generic Letter No. 82-12 on June 15, 1982.

The inspectors reviewed the Technical Specifications (TS), procedures and licensee correspondence with the NRC regarding overtime limits.  !

Overtime records covering four two-week pay periods at Braidwood, Dresden and LaSalle were reviewed to evaluate the amount of overtime usage.

Byron and Braidwood: Byron and Braidwood are required by Technical Specification 6.2.2.e to develop and implement administrative procedures to limit the working hours of unit staff, such as licensed sen'c.r operators, licensed operators, health physics personnel, equipment operators, and key maintenance personnel, who perform safety-related functions. The amount of overtime worked by unit staff members performing safety-related functions shall be limited in accordance with the NRC Policy Statement on working hours as contained in Generic Letter 82-12.

The inspectors determined that Byron and Braidwood have developed administrative procedures to satisfy the technical specifica, tion:

The procedures in place at the time of the inspection were Byron procedure BAP 100-7, (Revision 3, October 15,1986)," Overtime Guidelines for Personnel That Perform Safety Related functions "

and Braidwood procedure BwAP 100-7, (Revision 0, July 26, 1985),

" Overtime Guidelines for Personnel That Perform Safety Related Functions." Discussions with licensee representatives and a review of these procedures indicate that the licensee applies the procedure 2

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only to individuals who perform both safety-related work and who compose the TS required minimum shift complement.

During the time period inspected for Braidwood (56 days) the amount of overtime worked in days of 16' hours,by department, was as follows:

Operations - 316 instances where a 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> day was worked.

Maintenance - 174 instances where a 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> day was worked Radiological - 150 instances where a 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> day was worked 1

The total number of individuals working 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> days was not determined. ]

As indicated in the data where individuals worked consecutive days with i a 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> shift per day, it appeared that operations personnel exceeded the'24 in 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> limit on six occasions. Maintenance personnel. exceeded j the 24 in 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> limit on three occasions. Radiological / Chemistry personnel exceeded the 24 in 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> limit on 14 occasions, once with four consecutive 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> days and twice with three consecutive 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> days. The inspectors determined that all licensed operators met the policy but could not determine whether the other individuals were -

performing safety-related work as part of the shift complement to whom the GL 82-12 guidelines are applied or whether appropriate management approval was granted for this overtime.

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LaSalle: LaSalle is required by Technical Specification 6.1.C.7 to develop and implement administrative procedures to limit the working l hours of unit staff, such as, senior reactor operators, reactor operators, health physicists,. auxiliary operators, and key maintenance f j

personnel, who perform safety-related functions. The TS also states J that adequate shift coverage shall be maintained without heavy use of I overtime, but if unforeseen problems occur that require the use of substantial amounts of overtime, overtime shall be used following specified guidelines. The guidelines, specified in the TS, match the NRC policy statement. Deviations from the guidelines shall be authorized by the Production or Services Superintendent or higher g level of manag2 ment. The authorization shall be in accordance with procedures and the basis for the deviation shall be documented. The procedures are also required to include controls such that individual overtime shall be reviewed monthly to assure that excessive hours have

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not been assigned. Routine deviations from the hour guidelines in the TS are not allowed.

The inspectors determined that LaSalle has devel'oped administrative procedure LAP-100-17 (Revision 5. January 25,1988)," Overtime Guidelines for Personnel that Perform Safety Related Functions,"

to satisfy the TS. Discussions with licensee representatives, a review of the procedure, and a letter from the licensee to the NRC dated May 4, 1982, indicate that the licensee's applies the procedures only to individuals who preform both safety-related work and who ,

compose the TS required minimum shift complement. In the letter on l May 4, 1982, the licensee also states that they interpret the TS to j apply only during operational conditions 1, 2, and 3. This 4 l

interpretation is based on a statement in the March 1981 LaSalle SER that overtime restrictions apply except for " extended periods of l shutdown for refueling, major maintenance, or major plant modifications."

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o x During the time period inspected for LaSalle (56 days). the amount of '

overtime worked in days of 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> or longer by department, was noted as follows:

Operations - 196 instances where a 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> day was worked Maintenance - 441 instances where a 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> day was worked:

Radiological -L491 instances where a 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> day was worked The total number of individuals working 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> days was not' determined.

As indicated in the data where individuals worked consecutive days with a 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> shift per day, it appeared that operations personnel exceeded the 24 in 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> guideline on four occasions. Maintenance personnel exceeded the 24 in 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> guideline on 17 occasions. Radiation-Chemistry personnel exceeded the 24 in 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> guideline on 20 occasions. The inspectors determined that licensed operators met the policy but could not determine whether the other individuals were performing safety-related work as part of the shift to whom the GL 82-12 guidelines are applied or whether appropriate management approval was granted for this overtime.

1 Dresden: . Dresden is required by Technical Specification 6.2.A.14 to prepare, approve, and. adhere to detailed written procedures on working hours of the' Shift Engineer Station Control Room Engineer Shift Foreman, and Nuclear Station Operator job classifications such that the heavy use of overtime is not routinely required (a 15 with wording)nearly identical to the Dresden TS are in effect for Quad Cities and Zion . 4 Dresden has developed administrative procedure DAP 7-1, " Operations l Department Organization," to satisfy the TS. To strengthen admin-istrative controls, Dresden has also developed procedure DAP 7-21, (Revision 0, October 28, 1987), " Station Policy on Reactor Operator and Senior Reactor Operator Manning Levels and Overtime."

Dresden TS and procedures did not control the overtime of non-licensed operators, maintenance or rad ches personnel, however, in response to inspection report 237/8809(DRSS) a letter addressed to A. 8. Davis dated July 5,1988, the licensee comitted to applying guidelines to a " duty" radiation protection technician and a chemistry technician assigned to the safety-related duties. The licensee also provided the background of submittals made to satisfy NUREG-0737 Post-THI action item I.A1.3.1

" Limit Overtime". In attachment 1 of the response the licensee provided the following summary from a letter E. D. Swcrtz, Ceco Nuclear Licensing Administrator to D. G. Eisenhut. Director NRC Division of Licensing dated June 4, 1982:

  • We are in substantial compliance with both the NUREG-0737 and Generic Letter 82-02 requirements. The subject overtime limitation for the Shift Engineer, Shift Foreman, Station Control Room Engineer and the Nuclear Station Operator is administrative 1y covered by procedure.

For the additional job classifications identified in the NUREG and Generic Letter, Dresden maintains a sufficient number of personnel such l that overtime, even for extended outages, is not routinely scheduled to extend beyond a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> shift. Per the November 10, 1981 letter from ,

T. A. Ippolito to L. De1 George, the NRC Ste.ff has found that our previous j 1

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correspondence adequately addresses the shift manning overtime limit requirements. This item is considered complete."

For the time period inspected for Dresden (56 days), the amount of

. overtime worked in days of 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> or longer by department, was noted as follows: 7 Operations - 115 instances where a 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> day was worked L

Maintenance - 124 instances where a 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> day was worked l Radiological - 210 instances where a 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> day was worked The total number of individuals working 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> days was not determined.

l As indicated in the data where individuals worked consecutive days with L a 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> shift per day, it appeared that.the operations department exceeded th 24 in 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> guideline seven times, with three individuals working..three consecutive 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> days and one working four consecutive 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br />. days. Maintenance employees exceeded the 24 in 48 limit 15 times, with two individuals working four consecutive 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> days and lfive individuals working three consecutive 16' hour days. Radiation-Chemistry employees exceeded the 24 in 48 limit 40 times and the 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> -

in 7 days limit on three occasions when individuals worked five consecu-tive 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br />. days. Individuals also worked four consecutive 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> days on 12 occasions and three consecutive 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> days on six occasions.-

7 The . inspectors determined that licensed operators met the policy but could not determine whether the other individuals were performing safety-related work as part of the TS minimum shift complement to whom the GL 82-12 guidelines are applied, or whether appropriate management approval was granted for this overtime.

Quad Cities: Quad Cities has a Technical Specification (6.1.A.14) on overtime with the same requirements as the Dresden TS. Quad Cities has

- procedure QAP 300-3, (Revision 10, July 22, 1988), " Shift Manning," to satisfy the TS.

As with Dresden, the NRC accepted ::ubmittals for Quad Cities including exceptions from procedurally controlling overtime hours for the additional job classifications identified in GL 82-12 1.e. health

. physicists and key maintenance personnel.

Zion: Zion has a Technical Specification (6.1.1.M) on overtime with the same requirements as the Dresden's TS. Zion procedure ZAP-0 (Revision 1, September 11, 1987), *Cenduct of Operations," was imple-mented to satisfy the TS and is also similar to Dresden's. As with Dresden, the NRC accepted submittals for Zion including exceptions from procedurally controlling overtime for health physicist and key maintenance personne1.

3. Allegation (99024)

-(Closed) Allegation (RIII-88-A-103), maintenance and operations employees are working a lot of long shifts. This allegation was substantiated in that overtime records indicated that in the two month period some individuals had worked several consecutive 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> days. The records 5 l l

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a L, did not show that single' individuals were consistently working long shifts but that the overtime usage was spread over a number of employees.

I NRC's position on use of overtime is described in the policy on " Nuclear

-Power Plant Staff Working Hours" which applies only to certain job classifications performing safety-related work. A great majority of t.

- worker overtime does not fall under this policy. In addition. Aafety-p related overtime work reviewed and approved by station management is permitted by the policy. No deviations from the policy were identified; this allegation is. considered closed.

,. 4. Conclusion l

The sites where overtime records were reviewed (Dresden, LaSalle and Braidwood) each have different commitments governing overtime which have been approved by the NRC. The applicable site procedures accurately reflect these consnitments.

The use of overtime as indicated by the work records reviewed did not indicate any gross failure to meet the overtime guidelines. The data also did not reveal that overtime usage by individuals covered by the .

policy was routine or heavy although a few instances of heavy overtime (three or more consecutive 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> days) were identified. The inspectors determined that none were licensed operators working without appropriate

- approval. In some instances where overtime use was heavy, it was not possible to determine if the overtime involved safety-related work requiring approval by management. Overall, there was significant overtime usage spread over a large population of employees. Although no deviations from the overtime policy were identified, the following concerns were raised:

a. Some sites only apply the overtime guidelines to the TS minimum shift crew composition. This limitation does not appear justified .

~

as safety-ralated work is performed by personnel other than this crtw.

b. Overtime policies are not being uniformly applied at all sites.

For example, at Dresden the overtime policy is applied to the Radiation Protection and Chemistry Technician positions. There is'no indication that the overtime policy is applied to this same position at the other five sites.

c. Where the licensee committed to adequate staffing levels to meet the policy, it is not apparent from procedures or the time records provided that the licensee can effectively ensure that the overtime policy is being met.
d. The LaSalle Station appears to apply the overtime policy only during plant modes 1, 2, and 3. It is not clear that the overtime policy is implemented during refueling or major outages.

These concerns were discussed by telephone with the licensee on August 2, 1989. During the discussion, the licensee informed Region III that Ceco was just completing an internal review on the same matter and would respond to the above issues in writing.

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