ML20206U335

Forwards Evaluation of Matter Described in Re Byron Station.Concludes That Use of Overtime at Byron Station Was Controlled IAW Administrative Requirements & Mgt Expectations Established to Meet Overtime Requirement of TS

ML20206U335
Person / Time
Site:	Byron
Issue date:	04/30/1999
From:	Krich R COMMONWEALTH EDISON CO.
To:	Grobe J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20206U278	List: ML20206U272 ML20206U280 ML20206U288 ML20206U296 ML20206U300 ML20206U310 ML20206U316 ML20206U322 ML20206U326 ML20206U335
References
NUDOCS 9905250173
Download: ML20206U335 (10)

Text

05>24/93 17:10 FA.\ 630 515 1078 l.S..NRC REGION III goog

< . .n n i.. .e u i .m i, i a. , a .- luns

- i i oo op,,s n.u .

n. u nus onac na om s on j Comed April 30,1999 John A. Grobe, Director l

Division of Reactor Safety l

U.S. Nuclear Regulatory Commission l

Region til i 801 Warrenville Road Lisle, IL 60532-4351

Subject:

Additional Information Related to Byron Station Overtime -

NRC Tracking No. 98-A-0165

References:

(1) Letter from H. Brent Clayton (U.S. NRC) to O. D. Kingsley (Commonwealth Edison Company) dated October 30,1998 (2) Letter from K. L. Graesser (Commonwealth Edison Company) to H. Brent Clayton (U.S. NRC) dated December 8,1998 (3) Letter from K. L. Graesser (Commonwealth Edison Company) to H. Brent Clayton (U.S. NRC) dated December 22,1998 (4) Letter from John A. Grobe (U.S. NRC) to O. D. Kingsley (Commonwealth Edison Company) dated March 29,1999

Dear Mr. Grobe:

$$ Pursuant to your request, we are providing you a copy of our evaluation of the matter "8 described in Reference 4. As requested, this response is not being submitted on the y station docket. As discussed in a teleconference between R. M. Krich, Commonwealth gS Edison (Comed) Company, and S. Reynolds, NRC, on April 28,1999, the submittal nu date for this evaluation was extended from April 28,1999, to April 30,1999. The

• evaluation was conducted independently by the Comed Nuclear Generation Group O$ (NGG) Regulatory Services organization. We have determined that the investigation gg was of sufficient depth and scope to address the issues identified in Reference 4. The attachment does not contain any personal privacy, proprietary, or safeguards gg information.

z ui In Reference 1 the NRC requested that Comed provide the results of an evaluation of overtime concems at Byron Station. In References 2 and 3, we provided the results of our evaluation. In Reference 3, we concluded that the use of overtime at Byron Station was controlled in accordance with the administrative requirements and management expectations established to meet the overtime requirements of the Technical Specifications; overtime usage does not cross into the realm of routine; sufficient staffing has been and continues to be maintained to support the operational

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iM 2UWU 87:10 FAX 630 515 B@70 L.S.MC REGION 111

$002 April 30,1999 John A. Grobe Page 2 of 2 requirements of the station; and overtime at Byron Station has been, and continues to l

be, controlled in a manner consistent with safe plant operations. In Reference 4, the NRC requested that we provide additional information to further clarify these conclusions.

In summary, and as detailed in the attachment, after additional review of the overtime I issues, we have re-confirmed that the overtime controls specified in NRC Generic Letter 82-12,

• Nuclear Power Plant Staff Working Hours " and required by Technical Specifications Section 5.2.2.d, are being property implemented. In general, we have found that, on average, operations personnel do in fact work in excess of a 40-hour -

week during non-outage periods. Overtime use in the Byron Station Operations Department during non-outage periods has been averaging between one hour and eight hours per person per week during 1996,1997, and 1998. We do not, however, consider this amount of overtime per week to constitute " routine heavy use of overtime" as specified in Generic Letter 82-12. However, we are continuing to assess the use of overtime at Byron Station as well as our other nuclear stations to determine if the existing controls need to be reinforced.

Please contact Mr. J. A. Bauer at (630) 663-7287 if you have any comments or questions regarding this matter.

Respectfully, R. M. Krich Vice President- Regulatory Service

Attachment:

Evaluation Report NRC -Tracking No. 98-A-0165 l

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OL W 99 17ilo FAX 630 516 lon U.S..NRC REGIO.\ 111 f oo3 Attachment Evaluation NRC Tracking No. 98-A-0165

1. INTRODUCTION In a letter dated March 29,1999, the U. S. Nuclear Regulatory Commission (NRC),

Region 111, requested the following information conceming the Commonwealth Edison (Comed) Compny Byron Station.

1 Technical Specification 6.2.2.e states that the amount of overtime worked by facility j staff members performing safety-related functions shall be limited in accordance with the overtime limits specified in Generic Letter (GL) 82-12. Generic Letter 82-12 states that the objective is to have operating personnel work a normal 8-hour day,40 hour4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> J

week during plant operation; however, during unusual circumstances, and on a j temporary basis, additional limits for working overtime shall be followed. In addition, Generic Letter 82-12 states that deviations from those limits shall be authorized by plant management.

You concluded in your December 22,1998, response that overtime was not used to compensate for inadequate personnel staffing, was controlled in a manner that ensured compliance with Technical Specifications and Byron Administrative Procedure (BAP) 100-7, " Overtime Guidelines for Personnel," and did not cross into the realm of routine. )

The conclusion was based on the overtime yearly average per person remaining steady I since January 1995 and that the majority of overtime occurred during refuel outages.

You also concluded that based upon a review of licensee event reports, root cause

• evaluations, and other independent reviews that overtime usage had not adversely impacted operation of the Byron Station.

However, information provided in your response, including 4300 approved deviations from overtime guidelines from January 1995 through June 1998 and a consistently large number of average yearly overtime hours by operations personnel from 1996 through October 1998, appear to support a different conclusion in addition, NRC Inspection Reports 50-454/455-97012 (DRP) and 50-454/455-98005 (DRP) documented that licensed operators were normally working hours that exceeded the maximum overtirne limits specified by your administrative procedure.

Please provide the following information:

1. With respect to the above information including numerical data provided in your earlier response and NRC inspection findings, explain why you do or do not consider the operations department overtime usage " routine and excessive."

2. Your earlier response focused on yearly averages for overtime. However, yearly averages could mask individuals or groups of individuals with much higher than average overtime usage and the related potential safety impact, especially when the overtime is congregated during outages as you stated in j your response. Explain what actions you have taken to determine the extent  ;

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and safety impact of individuals with much higher that average overtime especially during peak usage times and your conclusions in this area.  ;

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3. In addition, please explain the roles of the Corrective Action Program and the l Nuclear Oversight Organization had in evaluating the use of overtime for l operations personnel and their roles in reaching the conclusion that the use of overtime was not routine or excessive."

11. EVALUATION DETAILS The Nuclear Generating Group (NGG) Regulatory Services organization conducted an independent evaluation of the information requested in a NRC letter dated March 29, 1999. The results are provided in the following responses.

Reauest No.1 "With respect to the above information including numerical data provided in your earlier response and NRC inspection findings, explain why you do or do not consider. the operations department overtime usage " routine and excessive."

Response

in order to provide a basis as to whether we do or do not consider the Operations Department overtime usage " routine and excessive," a re-review of the Byron Station Operations Department overtime details for Senior Reactor Operators (SROs), Reactor Operators (ROs), and Non-Licensed Operators (NLOs), was performed for 1996,1997, and 1998. The phrase " routine and excessive" overtime, used in Request No.1, is assumed to be equivalent to the phrase

• routine heavy use of overtime," used in Generic Letter 82-12, " Nuclear Power Plant Staff Working Hours."

The average amount of overtime was determined for the individuals in the positions of SRO, RO and NLO in the Byron Station Operations Department. Since this is an average, these figures do not mean that each person worked some overtime. These data are presented in the table below. The amount of overtime is given in average number of hours worked per person, and also expressed as a percentage above a normal 2080-hour work year. For example, if an SRO worked 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> of overtime in 1998, this would be listed in the table below as 5% (i.e.,100/2080 = 0.05).

Table 1 Byron Station Operations Personnel Average Amount of Total Overtime Worked per Person per Year Operations Group Total Overtime Total Overtime Total Overtime 1996 1997 1998

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SROs 119 hrs (6%) 342 hrs (16%) 320 hrs (15Toi ROs 446 hrs (21%) 611 hrs (29%) 548 hrs (26%)

NLOs 401 hrs (19%) 452 hrs (22%) 391 hrs (19%)

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--- q3; gg--- lI* W M M M AMO U.S.SRC REGION III [g (303 Many of the overtime hours worked are attributed to outage-related activities. In 1997, the peak year for overtime, there were a total of seven outages, i.e , six forced outages and one refueling outage, for a total of 103 days of outage time.

The amount of non-outage overtime worked in the Operations Department was then determined. Operations non-outage overtime hours were calculated by subtracting all overtime hours worked during outage periods from the total operations overtime hours.

An average of Operations personnel non-outage overtime hours worked are given in Table 2 below. Again, these figures do not reflect that each operator worked overtime since these are average values.

Table 2 -

Byron Station Operations Personnel Average Amount of Non-outage Overtime Worked per Person per Year Operations Group Non-outage Overtime Non-outage Overtime Non-outage Overtime 1996 1997 1998 SROs 61 hrs (3%) 227 hrs (11%) 174 hrs (8%)

ROs 221 hrs (11%) 401 hrs (19%) 326 hrs (16%)

NLOs 185 hrs (9%) 308 hrs (15%) 240 hrs (12%)

Overtime use in the operations department during non-outage periods, as shown in the above table, has been averaging from 3% (i.e., approximately 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> per week per person for SROs in 1996) to 19% (i.e., approximately 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> per week per person for ROs in 1997). This average non-outage overtime reflects the need for individuals to work some amount of overtime due to a number of causes, including coverage for vacations and absence.s. Also, as discussed in response to Request No. 2 below, a review of overtime hours worked by individuals was conducted to ensure that routine and excessive use of overtime by individuals or groups was not masked by the average figures. According'y, we do not consider the rarce of overtime presented above as

" routine heavy use of overtime" as specified in Ganeric Letter 82-12. " Nuclear Power Plant Staff Working Hours."

3644 overtime deviations were approved from January 1995 through June 1998. In our letter from K. L Graesser (Comed) to H. Brent Clayton (NRC), dated December 22, 1998, we indicated that 4300 overtime deviations were approved during this time period. Upon further review, this number was found to be in error, due to a tabulation mistake, and is actually 3644 as noted. A sample of these overtime deviations, from February 1998 through December 1998, was reviewed to determine the reasons for the overtime deviations and to identify which overtime guideline deviations were approved.

432 deviation forms were identified which addressed 790 different overtime deviations.

Note that more than one overtime deviation can be documented on the same form.

The deviation form will count two occurrences for an individual who exceeds the 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> over a seven day period guideline who may have also exceeded the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> over a 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> period guideline during that same seven day period. Of the 432 overtime deviation forms' approved,328 (i.e.,76%) were outage-related. The remaining overtime deviation forms were related to activities such as non-safety related administrative activities (e.g., work planning and scheduling), safety-related administrative activities (e.g., review of surveillance tests and out-of-service documentation preparation), root cause investigations, security manning, and training.

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!!.S.NRC REGION 111 If006 The most prevalent overtime guideline deviation, i.e., greater than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in a seven day period, occurred during outages. The rest of the overtime guideline deviations were spread across the other guidelines, i.e., less than 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> break between work periods, working greater than 16 consecutive hours, working greater than 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> in a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period, and working greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in a 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> period.

Finally, a review of the Byron Station Operations Department personnel staffing during 1995,1996,1997, and 1998 was performed to determine if there were staffing reductions that may have impacted the amount of overtime worked. The personnel numbers are given below.

Table 3 By on Station Operations Department Personnel Numbers Operations Department Personnel Numbers 1995 1996 1997 1998  !

152 166 166 172 As can be seen, Byron Station Operations Department staffing was increased by 20 individuals from 1995 to 1998.

NRC Inspection Report,50-454/455-97012 dated August 22,1997, and NRC Inspection Report 50-454/455-98005 dated March 16,1998, documented the NRC's j review of overtime issues at Byron Station. In the March 29,1999. NRC letter, it was j stated that these reports " documented that licensed operators were normally working hours that exceeded the maximum overtime limits specified by your [ Byron's]

administrative procedure." After reviewing these inspection reports, we could not j validate this statement.

NRC inspection Report 50-454/455-97012 stated, "The inspectors concluded that licensee management was aware of the amount of overtime worked in the operations department, controlled the overtime appropriately, and was working to reduce the number of hours required by hiring additional staff. Although a significant amount of overtime was worked from January through May 1997, there was no evidence that plant safety was compromised." This inspection Report also stated, "The inspectors did not identify any violations of licensee or NRC requirements."

NilC Inspection Report 50-454/455-98005 stated in part that the inspectors

.,. reviewed the overtime hours for seven nuclear station operators (NSOs) and three senior reactor operators (SROs) for the period November 7,1997, until February 2, 1998. The period, almost 12 weeks, was entirely an outage period for Unit 1."

Inspection Report 50-454/465-98005 went on to state that, "The inspectors concluded that the nuclear station operators (NSOs) were working large amounts of hours just under the overtime guidelines for extended periods of time. The inspectors did not identify any significant deviation from the overtime guidelines. However, the inspectors concluded that generally, the 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> shifts worked by the NSOs caused large amounts of overtime hours and the 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> shifts caused long periods of work without a day off.

Additionally, the 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> shifts caused excessive shift rotation. The inspectors concluded that the large amounts of hours worked by some NSOs and the extra shift 4

0.1 20/ W P/:32 m G M WD G M/t U.S.hRC REGION I11 g 007 rotations caused by the 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> shifts were poor human factor practices." This Inspection Report also noted, "The overtime hours for the three SROs reviewed appeared w;ll controlled."

We concur with the observations noted in inspection Report 50-454/455-98005 regarding outage overtime. Given the high level of activity during outage periods, we, I

would anticipate that many personnel, in all station departments, will continue to work a substantial amount of overtime during outage periods, as recognized in the guidance in Generic Letter 82-12. Limitations on overtime will continue to be controlled consistent with Byron Administrative Procedure (BAP) 100-7, " Overtime Guidelines For Personnel," which implements the requirements of Technical Specifications Section 5.2.2.d. .

Based on the above analysis and discussion, we have concluded that, although the use of overtime at the Byron Station requires continuous management attention and oversight, the overall control of overtime at Byron Station has been carried out in accordance with the requirements in the Technical Specifications. Accordingly, our re-review of overtime data confirms our previous conclusion that the Operations Department overtime usage is not " routine and excessive."

Request No. 2 "Your earlier response focused on yearly averages for overtime. However, yearly averages could mask individuals or groups of individuals with much higher than average overtime usage and the related potential safety impact, especially when the overtime is congregated during outages as you stated in your response. Explain what actions you have taken to determine the extent and safety impact of individuals with much higher that average overtime especially during peak usage times and your i conclusions in this area."

Response

Byron Administrative Procedure (BAP) 100-7," Overtime Guldelines For Personnel,"

implements the overtime guidelines specified in Generic Letter 82-12." BAP 100-7 requires documented authorization for deviations from these guidelines on form BAP 100-7T1, " Overtime Deviation Authorization." As applicable, this form requires the supervisor to evaluate the employee's potential for reduced effectiveness during a face to face meeting as soon as practical but prior to exceeding the overtime guidelines.

This form would be completed prior to an employee:

1. working with less than 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> rest between work periods; or

2. working greater than 16 consecutive hours; or

3. working greater than 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> in a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period; or

4. working greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in a 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> period; or

5. working greater than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in a 7 day period.

Unless an employee is specifically authorized to exceed one of the overtime guidelines, there is no specific action taken to evaluate and document an employee's fitness for duty due to potential fatigue. Therefore, an individual with much higher than the average overtime, would not receive any additional evaluation provided that individual remained within the overtime guidelines. However, it should be noted that all 5

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employees are continuously observed in accordance with the requirements of the Comed Fitness For Duty Program as defined in Corporate Nuclear Guideline No. 200,

" Comed Fitness For Duty Program." This guideline states that each individual employee has the responsibility of " reporting to their supervisor when any conditions exist which impairs 01eir ability to safely perform their assigned duties." Also, supe'rvisors are responsible for " familiarizing themselves with their employee's behavior pattems in order to enable the supervisor to recognize when an employee is exhibiting unusual or aberrant behavior." In addition, supervisors are responsible for " acting in a timely manner when a Fitness For Duty concem has been identified, if someone's fitness is questionable, the supervisor shall immediately remove the person from work activities." Therefore, at any time, if a supervisor observes that an employee is unfit to perform their work duties due to fatigue, the supervisor is obligated to remove that ' .

person from their assigned duties.

The specific concem in issue No. 2 that " yearly averages could mask individuals or groups of individuals with much higher than average overtime usage and the related potential safety impact," is a valid issue and of concem to us. Table 4 shows the average overtime of SROs and ROs as compared to the highest individual for each work group.

Table 4 Byron Station Operations Personnel Average / Highest Amount of Total Overtime Worked per Person per Year Operations Total Overtime Total Overtime Total Overtime Group 1996 1997 1998 i Avg / Highest Individual Avg / Highest Individual Avg / Highest Individual SROs 6% / 41% 16 % /48% 15 % / 36 %

ROs 21 % /34 % 29% /46% 26 % / 37 %

lt is clear that there is a significant variance between the average amount of overtime worked by SROs and ROs as compared to the highest amount of overtime worked by a specific individual. Byron Station senior management will continue to ensure that all I I

personnel either meet the overtime guidelines in BAP 100-7, or receive the appropriate management pre-approval with the corresponding face to face evaluation prior to j working the overtime. l A Byron Station overtime self-assessment was recently completed on April 26,1999.

This self-assessment evaluated operational events from June 1998 through present to determine if there was any link between the events and excessive operator overtime.

The self-assessment concluded that there was no direct or indirect link between any operational event and operator fatigue.

Request No. 3 "In addition, please explain the roles of the Corrective Action Program and the Nuclear Oversight Organization had in evaluating the use of overtime for operations personnel and their roles in reaching the conclusion that the use of overtime was not routine or excessive."

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Response

Corrective Action Program Role Root Cause Evaluations that addressed human performance errors, as well as other independent reviews of station performance, were reviewed to determine what effect the use of overtime may have had on plant operations. Itwas the conclusion of the Nuclear Oversight evaluators that overtime usage had not adversely impacted operation of Byron Station.

Nuclear Oversight Organization Role After receiving the October 30,1998 NRC letter, the corporate Nuclear Oversight Organization conducted an evaluation of overtime usage at Byron Station. The Nuclear Oversight Organization focused specifically on the use'of overtime by SROs, ROs, and NLOs at Byron Station.

Specifically, the Nuclear Oversight Organization performed the following activities.

1. Nuclear Oversight personnel met with Comed Corporate. Security and Regulatory 1 Services personnel to discuss the nature and scope of the NRC requested evaluation.

2. Nuclear Oversight personnel reviewed a variety of information and data regarding plant performance, human performance errors, overtime usage, and assessments of overtime usage at Byron Station.

As a result of their review, the Nuclear Oversight Organization reached the following conclusions that were provided in our December 22,1998 letter.

1. Overtime usage at Byron Station remained relatively constant since the January 1995 NRC violation regarding the control of overtime. Since the overall average amount of overtime had not varied greatly over the three year period in question (i.e.,1996,1997, and 1998); and the total amount of overtime in the Operations Department for this three period averaged 373 hours0.00432 days <br />0.104 hours <br />6.167328e-4 weeks <br />1.419265e-4 months <br /> per person per year (i.e.,

approximately 7.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> per week per person), it was concluded that the use of overtime was not excessive.

2. Overtime usage had not adversely impacted the operations of Byron Station based on the fact that no operational events had been identified that were associated with operator fatigue.

3. Overtime usage at Byron Station had not crossed into the realm of routine as defined by Byron Administrative Procedure 100-7, " Overtime Guidelines for Personnel."

1 This conclusion was reached based on a review of the Operations Department I staffing in order to determine whether overtime was being used routinely to compensate for inadequate staffing. It was the conclusion of the Nuclear Oversight evaluators that overtime was not being used to compensate for inadequate staffing.

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4. The corrective actions taken in response to the violation cited in NRC Inspection Report 50-454/455 94025 had been effective in reducing, but not totally eliminating,

~ the occurrences of "after the fact" overtime approval.

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5. While not a problem of routine or excessive use, overtime was a recognized )

concem across the Nuclear Generation Group as the use of overtime pointed towards inefficiencies in the processes used to accomplish daily work activities.

Ill. CONCLUSION -

1. We have re-confirmed that the control of overtime specified in Generic Letter -

i 82-12 is being properly implemented. We do acknowledge that, in general, j Byron Station operations personnel do in fact work overtime during non-outage periods. Overtime use in the Operations Department during non-outage periods  !

has been averaging approximately one hour to eight hours per person per week in 1996,1997, and 1998. We do not, however, consider this to constitute l

" routine heavy use of overtime" as specified in Generic Letter 82-12.

2. It is recognized that there is a significant variance between the average amount of overtime worked by SROs and ROs as compared to the highest amount of overtime worked by a specific individual. Anyone working in excess of the guidelines of Byron Administrative Procedure (BAP) 100 7, " Overtime Guidelines For Personnel," will receive management authorization prior to performing the work. Further, each employee being approved for an overtime guideline deviation will be evaluated as required by and documented on form )

BAP 100-7T1. This form requires the supervisor to evaluate the employee's 1 potential for reduced effectiveness during a face to face meeting as soon as practical but prior to exceeding the overtime guidelines.

A Byron Station overtime self-assessment was recently completed on April 26, 1999. The self-assessment concluded that there was no direct or indirect link .

between any operational event and operator fatigue.

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3. Root Cause Evaluations that addressed human performance errors, as well as other independent reviews of station performance, were reviewed to determine

. what effect the use of overtime may have had on plant operations. It was the conclusion of the Nuclear Oversight evaluators that overtime usage had not adversely impacted operation of Byron Station.

The Nuclear Oversight organization conducted an evaluation of overtime usage at Byron Station. The Nuclear Oversight organization focused specifically on the use of overtime by SROs, ROs and NLOs at Byron Station. The Nuclear Oversight organization concluded that overtime use was not excessive; overtime usage had not adversely impacted the operations of Byron Station due to operator fatigue; and overtirne usage at Byron Station had not crossed into the realm of routine.

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