ML20043D769

Responds to 900501 Ltr Re Work Hours for Dickherber.During Outage,Dickherber Worked Extended Hours Traditionally Associated W/Refueling Activities

ML20043D769
Person / Time
Site:	Quad Cities
Issue date:	06/04/1990
From:	Galle D COMMONWEALTH EDISON CO.
To:	Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20043D767	List: ML20043D766 ML20043D769
References
EA-90-031, EA-90-032, EA-90-31, EA-90-32, NUDOCS 9006110154
Download: ML20043D769 (7)

Text

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Commonwealth Edison '

2 1400 Opus Place E Downers Cr:ve, lilln:Js60515 J

June 4, 1990 Mr. A. Bert Davis Regional Administrator ,

Nuclear Regulatory Commission 799 Roosevelt Road

• Clen Ellyn IL 60137

Subject:

In the Matter of R. L. Dickherber, License No. SOP-2365-8, ,

Docket No. 55-5043, EA 90-031 and In the Matter of '

Commonwealth Edison Company, Quad Cities Nuclear Power Station Docket Nos. 50-254 and 50-265, License Nos. >

DPR-29 and DPR-30 and EA 90-032 Referencess (a) J. Lieberman to Cordell Reed letter ,

dated May 1, 1990.

(b) S.R. Lefstein to J. Lieberman letter I dated April 13, 1990.

Mr. Davis This is in response to the reference (a) letter which states, in part, as follows:

' "As a separate matter, please provide to the. Regional Administrator Region III, your views concerning the adequacy of the company's controls for work hours in view of the information provided by l Mr. Dickherber on page 13 of his answer." -

Attachment A provides our discussion of work hour controls, as requested.

We have conducted a review of Mr. Dickherber's work hours. That review did not substantiate his stateseents concerning overtime. On June 1, l 1990, Mr. Dickherber did submit a clarification and retraction of certain '

parts of the statements contained in his April 13, 1990 response. Attachment i B provides a weekly summary of the hours worked by Mr. Dickherber from January ,

2, 1990 through the date (October 17, 1989) of the event that prompted these l consnun iques .

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L 9006110134 900604 ,

PDR ADOCK 05000?54

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.i Finally, we believe that our controls over work hours have been offective and will continue to ensure a high level of compliance with the i NRC's guidelines on overtime as well as provide assurances that our personnel  !

are not working to the evtont that fatigue would impair their performance. [

If your staff has any questions or comunents regarding this gubmittal, l please refer them to Ms. Rita Stols (708) 515-7283.  !

Sincerely yours.

P Dennis Galle A% &Yb '

90 Vice President j BWR Operations  ;

i cc: J. Lieberman, Director, Office of Enforcement '

J. Zwolinski, Assistant Director, NRR L. 01shan, Project Manager, NRR W. Shafer, Branch Chief, RIII J. Hind, Section Chief, RIII Senior Resident Inspector, Quad Cities '

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l ATTACHMENT A C0f990NWEALTH EDISON CONTROLS OF HOURS WORKED l

I Conunonwealth Edison's controls over the number of hours worked by its employees in nuclear power plants are divided into two categories depending on how the individual's activities affect the safety of plant operation.  ;

Personnel who are directly involved with the operation or maintenance of safety-related plant equipment are encompassed by a formal program for ll monitoring work hours in accordance with Generic Letters 82-12 and 83-14.

Work hours for other personnel whose activities do not directly or immediately impact the safe operation of the plant are monitored by more traditional .

management techniques.

Currently, Cosenonwealth Edison's control over work hours for plant personnel who perform safety-related functions is implemented through Nuclear ,

Operations Directive. 0A.13, revision 0 dated December 31, 1989. This ,;

directive became fully effective on April 30, 1990. It incorporates the guidance contained in Generic Letter 82-12 and 83-14 and Cosusonwealth Edison's conunitments in its NRC approved programs to control overtime hours.

The current Directive was developed following a coaprehensive review of practices at each of our Nuclear Stations.. Cosusonwealth Edison's adoption of the directive assures that overtime controls are applied uniformly to specific Station positions consistently throughout our Nuclear Stations. In addition to providing a consistent policy, the Directive expanded the scope of the coverage to include additional positions that were not included prior to formalizing our approach in Nuclear Operations Directive OA.13. Positions currently encompassed by this Directive includes the Operating crew, ,

Maintenance crews, Fuel Handling Foreman (during fuel movement), one Radiation Protection and one Chemistry Technician. The Directive requires that deviations be approved by the Station Manager or responsible supe" visor (for call-out situations) prior to deviating.from the guidelines. 1 The current Directive also includes an oversight procedure to ensure j compliance. That procedures requires that deviations from the Directive- ,

guidelines be reported to upper Station Management on a monthly basis and to senior Corporate Management on a semi-annual basis. Included in the reports are the number of personnel who exceeded the guideline. In addition, the report to senior Corporate management requires that actions to prevent recurrence be defined, if the guidelines were exceeded without proper approval.

l For personnel who are not encompassed by the guidance contained in the Generic Letters, management relies on the traditional methods of both personal awareness and supervisory observation to ensure that individuals are not fatigued by working excessive hours. When individuals believe they are becoming fatigued or are so observed by their supervisors, the work [

assignments-for those individuals are adjusted accordingly. For non-salaried employees, overtime sheets are required to be approved by Supervisors. This permits each Supervisor to review the hours worked by his/her subordinates l during a two-week pay period and to adjust subsequent work schedules, if 1

Attachment A (continued) appropriate. For salaried employees, during periods of high activity such as a Refueling Outage, individuals must complete special forms to receive compensation for extended hours. Because such compensation requires the approval of supervisory personnel, supervisors review extended hours worked and can adjust subsequent assignments accordingly. In addition, management monitors work group overtime hours on a quarterly basis. This enables management to identify work groups with substantial overtime and to use this information to plan future work activities. While this approach is less formal than required by the Directive, experience has shown that this approach is effective and appropriate for assuring that personnel do not work excessive hours as a matter of course.

As Mr. Dickherber's supplement has clarified, the ef fectiveness of Commonwealth Edison's controls of overtime hours is not contradicted by Mr.

Dickherber's record of work hours. At the time of the incident, the Fuel llandling Foreman was not encompassed by the formal program for monitoring work hours covered by the Generic Letters. Nevertheless, in our response dated March 26, 1990 Commonwealth Edison noted that the numerical limits in the overtime guidelines were exceeded in a few of cases by no more than two hours based on NRC allowances for turnover. This conclusion has now been corroborated by Mr. Dickherber's clarification of June 1,1990, in which he has clarified his previous statements regarding hours worked. That clarification essentially shows that from the beginning of 1989 until shortly before the Refueling Outage, Mr. Dickherber worked the normal hours for plant personnel, that shortly before the outage Mr. Dickherber took a vacation and j that during the outage Mr. Dickhetber worked the extended hours traditionally i associated with refueling activities. For clarity, a summary of Mr. j Dickb*rber's weekly hours are provided in Attachment B.

For these reasons, Commonwealth Edison believes that its programs for ,

controlling overtime hours comply with the Commission's guidelines where '

applicable and otherwise provide ef fective work controls for individuals in nuclear power plants.

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ME .

R. DICEIERBER 1989 M ME E0tRS 1989 '

Mon. thru Sun. PA Computer Training Other Facation/ Holiday -

Period Hours Hours Hours Total Hours P- -- tm .

01/02 - 01/08 35.5 35.5 8 Holiday 01/09 - 01/15 35.5 35.5 01/16 - 01/22 41.5 41.5 01/23 - 01/29 36.0 36.0 01/30 - 02/05 43.5 43.5 02/06 - 02/12 45.0 45.0 02/13 - 02/19 24.5 24.5 16 Holiday & 1 Vacation Day 02/20 - 02/26 36.0 36.0 8 Holiday .

02/27 - 03/05 54.0 1 55.0 Radiation Training 03/06 - 03/12 41.5 7 48.5 Rockford 03/13 - 03/19 43.0 43.0 03/20 - 03/26 35.0 35.0 8 Holiday 03/27 - 04/02 45.5 45.5 04/03 - 04/09 26.0 26.0 04/10 - 04/16 36.0 36.C 04/17 - 04/23 35.5 35.5 04/24 - 04/30 35.5 8 43.5 Conduct of Ops Training

.05/01 - 05/07 01.5 40 41.5 Instp Training 05/08 - 05/14 44.0 44.0 05/15 - 05/21 44.0 44.0 05/22 - 05/28 22.0 22.0 05/29 - 06/04 32.5 32.5 8 Holiday 06/05 - 06/11 29.5 29.5 8 Vacation 06/12 - 06/18 45.0 45.0 06/19 - 06/25 16.0 7 23.0 24 3 Vacation Days, Rockford 06/26 - 07/02 36.0 8 44.0 07/03 - 07/09 27.0 27.0 8 Holiday 07/10 - 07/16 57.0 57.0 07/17 - 07/23 10.0 40 50.0 Fuel Handling Training 07/24 - 07/30 26.0 40 66.0 Fuel Handling Training 07/31 - 08/06 27.0 40 67.0 Fuel Handling Training 08/07 - 08/13 65.0 65.0 08/14 - 08/20 37.0 7 44.0 Station Annual Retraining 08/21 - 08/27 40.5 3 43.5 Fitness for Duty Training 08/28 - 09/03 24.0 24.0 09/04 - 09/10 0.0 0.0 40 Holiday & 4 Vacation Days 09/11 - 09/17 79.0 79.0 09/18 - 09/24 61.0 61.0 09/25 - 10/01 64.0 7 71.0 Rockford 10/02 - 10/08 56.0 56.0 10/09 - 10/15 68.0 68.0 10/16 - 10/22 60.0 60.0

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a.w.3.=stmo ev.,,..uv. news owa nm 2379-1 FAX AND U.S. MAIL DELIVERY i James Lieberman, Esq.

Director, Office of Raforcement j OWPN 7H4 United States Nuclear Regulatory Commission Washington, DC 20555  ;

Ret In the Matter of R. L. Dickharber License No. SOP-2365-8 Docket No. 55-5043 EA 90-131 and In the Matter of Commonwealth Edison Company '

Quad Cities Nuclear Power Station Docket Nos. 50-254 and 50-256 i License Nos. DPR-29 and DPR-30 '

E1 90-032

Dear Mr. Lieberman:

1990, Submitted to you by FAX and thereafter by mail on June 1, is the Supplemental Answer of Robert L. Dickherber. We previously advised - Mr. Berson of Region III that this document would be submitted, and in response to my inqui:.7, he.adviced that no motion for leave to file this document was necess.'.ry.

Also enclosed is a Proof of Service with an attached' service Thank you for your attention. j Sincerely, i bdO h M-f-Stuart R. Lefstein i SRL/mlh ,

)

Encl.  ! l

+ 4 KATz, McANDREWS, BALCH, LersTEIN & Fitwtorm, P.C.

i James Lieberman, Esq.

June 1, 1990 Page 2 Copies by FAX and U.S. Mail to:

Mr. Charles Bechoefer, Chalunan of Administrative Judges Assistant General Counsel for Esarings and Enforcement Regional Administrator, NRC Region III Sheldon L. Trubatch, Esq.

Michael Miller, Esq.

Copies by U.S. Mai.1 only tot _.

Secretary, U.S. Nuclear Regulatory Commission Senior Resident Inspector at Quad Cities Nuolaa.r Power Station  !

6 4

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UNITED STATES-NUCLEAR REGULATORY COMMISSION IN THE MATTER OF: ): License ~No. SOP-2365-8

)- Docket No. 55-5403 R. L. DICKEERBER, ) EA 90-031

___)

IN THE MATTLA OF -- ) ' .

l- ) License Nos. DPR-29 & DPR-30 l' l COMMONWEALTE EDISON COMPANY )- Docket Ncs.-50-254 & 50-256 l .

QUAD CITIES NUCLEAR POWER -) EA 90-032 L STATION )-

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PROOF OF SERVICE ~

4

I, Stuart R. Lefstein,'an attorney for Robert L.  ;

.i Dickherber, having been sworn on oath, state that copies of' -i Supplemental Answer of Robert L. Dickberber were' served upon.  ;

the Agencies and persons on the attached Service List by '

Un; .ad States Mail, postage L prepaid, on June 1,-:1990. i Additionally, copies of that Supplemental Answer were served'  ;

l by Fax on June 1, 1990 to the first six-agencies or persons 1 named on the attached service list.

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Stuart R. Letstein% ,

Signed and sworn to before me, a Notary Public, this 'i i

ist day.of June, 1990.

1

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l Notary Public

']

Stuart R. Lefstein

, KATE, McANDRENS, BALCH,~LEFSTEIN & FIEWEGER, P.C.-

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j^o bn '5b; O l 200 Plaza Office Building MARILYN L. HACKER 0  ?!

Notmy Pubuc, Stm of lHinois l! -!

Roc I n L 61204-3250 compyq y~agn ,

Telephone: 309-788-5661

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_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _. _ _ . wr_,... - ,_,.. , .-. 4,-. m,

SERVICE LIST l

Charles Bechhoefer, -

-Chairman of Administrative Judges l l

Aromic Safety.and Licensing Board Nuclear Regulatory Commission.

4350 E-W Eighway -

Bethesda,lu) 20852 Director  !

Office'of Enforcomant i

U.S. Nuclear Regulatory Commission Washington, D.C. . 20555 i Assistant General Counsel Attn Eugene J. Boller, Esq. 't Hearings and Enforcement i U.S.-Nuclear Regulatory Commission; '

Washington, D.C. 20555-i Regional Administrator Attna Bruce Berson, Esq.

Regional Counsel.

U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137 i

Sheldon L. Trubatch, Esq. '

Sidley & Austin Attorneys for Commonwealth Edison Company ,

1722 I(eye) Street, N.N.

Washington, D.C. 20006~ i Michael Miller, Esq. i Sidley & Austin H Attorneys for. Commonwealth Edison Company

• One First National Plaza Chicago, IL 60603

?

Secretary Attnt. Chief, Docketing and Service Station Nuclear Regulatory Commission Washington, D.C. 20555 '

k Senior Resident Inspector Quad Cities Nuclear Power Station 22715 - 206th Avenue North Cordova, IL 61242

_. ~ _ . . __. _

. .: J I

UNITED: STATES NUCLEAR REGULATORY COMMISSION IN THE MATTER OF: ) License No. SOP _2365 8

) Docket-No. 55-5403 )

R. L. DICIEERBER -)- P2 90-031 .

______________ ) 1 IN THE MATTER.OF: )

) License Nos. DPR-29-& DPR-30 Docket Nos. 50_254 & '50-256 COMMONWEALTH EDISON: COMPANY:- ) I QUAD-CITIES. NUCLEAR POWER ). EA 90-032 -l STATION ) l 1

l SUPPLEMENTAL ANSWER OF ROBERT _L. DICF"RSER i

I, Robert ,L.  : Dickherber, hereby submit this Supplemental: ,

Answer, under oath, , to the Answer that I previously filed 'on April 13, 1990. My reason for submitting this . answer .is 7 that further information has come to my attention which I believe' requires; a -

withdrawal of certain statements previously made and a correction j of misleading implications that may flow from those statements.

Specifically, in - Section II: C, appearing ' on . p. 13 _ of my Answer, I made certain statements regarding time worked preceding the incident. The statements made were based on my best y reccllection and memory without having reviewed any' time records,;

with one exception bereafter noted.

. As a result of the Commission's directive 'to Commonwealth

(

L Edison to comment on the ' hours I' worked, that company developed hours information based upon its computer showing entry access and exit to and from the Cordova Station. Commonwealth has now made  !

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this information available to me and my attorney.1 '

n After reviewing this information, I' find it necessary to

withdraw and disavow the statements in the first two paragraphs 'in-Section II C appearing on p.13, except the first sentence which ~

concludes that the incident "was probably occasioned by stress" and-l the middle' sentence of the second paragraph relating . to the. .l

. cleaning of the fuel pool. A study of the hours'information from the computer simply does not support my recollection of the average amounts of time I said -I was working prior to the . incident in <

question.2 It should be noted, however, that my est %

1 of work hours in- thou two paragraphs were offered n- s background-information, and not as a cause of my conduct, . che day of the l-incident. Unfortunately, because I did not regard my hours as a-L reason for my actions, verification of them did not loom as an 1

Commonwealth Edison and its counsel have - been most cooperative in ~ honoring reasonable . requests for. pertinent 1 documents. Undoubtedly, had time- records ; covering the periods '

mentioned in my Answer been requested Commonwealth would have supplied them. Indeed, prior to preparing my Answer and without any request, the company had provided documents relating to my overtime hours from October 9 through ' October 21,- 1989, and a computer report showing the times of my entrances and exits to and from the security area of the-Cordova Station covering the period of October 2 through October 19, 1989. (Ex. 2 attached)' .

2 The hours information developed from - the computer shows time spent at the Cordova Station within the protected area, but I not work hours as such. Attached as l'rhibit 1 is a summary of q information taken from the computer relating to the specific l statements on p. 13 which .I am now withdrawing. While I believe l my hours worked were greater than the hours I was shown to be in l' the protected area, since et times I worked outside the protected area - (again, see Ex. 1 ) , these additional hours are not sufficient to substantiate my initial statements appearing in my Answer.

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3 important consideration in preparing -my Answer. However, upon further review of the first paragraph on p.13, I can see how the proximity of the statements regarding my 1989 hours0.023 days <br />0.553 hours <br />0.00329 weeks <br />7.568145e-4 months <br /> to the sentence i

that "the incident. . .. was probably ' occasioned by stress" could convey an impression that the stress .' resulted from those hours.

I an therefore speci.fically disavowing . any - such impression' . that- .i might: have been inadvertently created.3 I apologize to the  !

Commission _ and express my deepest regrets for having possi.bly created this impression and for relying on what is now shown to be.

7 a faulty memory with respect to my hours when they could and should-have been verified, at least to the extent' possible.5 i i

I continue to believe, as previously stated, . that " stress" "probably occasioned" the incident -in question es'sentially because of the reasons set forth in the. last paragraph commencing on p.13 t

of my Answer. To a minimal artent my ' hours within ' the protected l

area in the immediate days 5 and week before the ?i ncident' (which f were 72.5 instead of 81 , Ex.

2 attached) may' possibly have influenced my conduct. '

My misstatement that I worked 81 hours9.375e-4 days <br />0.0225 hours <br />1.339286e-4 weeks <br />3.08205e-5 months <br /> in the week immediately .

before the incident i.nstead of 72.5, which is the number shown on I 3

Note uti statement in the last paragraph on p. 12 of my Answer relating to a dropped fuel bundle occurring in September 1985 which was handled according to proper procedures. Obviously, neither stress nor prior hours worked affected my performance on that occasion. 1 4

See notes 1 & 2, suora, j

5 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> on october 15 and 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> on October 16.

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e

• 4 the computer, results from an i.ncorrect reading and impression of b

a . station management document' (Ex. 2)- first seen by me shortly '

af ter the incident. It was my impression that the 81 hours9.375e-4 days <br />0.0225 hours <br />1.339286e-4 weeks <br />3.08205e-5 months <br /> figure

shown on the document represented the number of hours 'that'. I had '

worked during the week preceding the.1.ncident. Since filing my Answer on April 13, 1990, I have determined that 'the 81' . hours figure, which appears next to arrows --drawn between days, is .the total hours I was in the protected area for 8 days prior to the c incident instead of 7.

My attorney and-I had a copy of Exhibit 2 available prior to '

preparing my Answer. Unfortunately, we failed- to critically.

examine it and instead simply relied on my mistakentimpression that it represented the hours for the week preceding the incident. My' attorney. and I both apologize for having not ' detect'ed . ? this L

incorrect impression when we had an opportunity to do so.  !

In attempting to assess the reasons for my inaccurate memory i and recollection, .I assume -that I was influenced by hours - worked -

during the month of September and that with respect to that month and earlier months I focused on the days where I worked long hours, l and that those days- then became exaggerated in my mir.d.as the norm.

For example, on September 13 I was in the protected area for 14 ,

hours and in the 7-day period: from Saturday, September 16 through

-Friday, September 22, the computer shows that I was in. the.

protected area for 82.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />, with a 13.5 hour5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> day on Saturday, a 13 hour1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> day on Sunday, a 13 hour1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> day on Thursday, a 12.5 hour5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> day on Friday, and al.1 days in that period at least 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />.

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In the days -immediately-preceding the day of- the incident the I

computer shows I was in- the protected area for 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> on Sunday, 7 October 15, and 13 honrs on Monday, October -16. My inaccurate perception that I . had worked 81 hours9.375e-4 days <br />0.0225 hours <br />1.339286e-4 weeks <br />3.08205e-5 months <br /> in . the week; preceding the -  !

incident probably also contributed to my incorrect statements-about L average hours.-

Similarly, in earlier months I had a few days'wliich were quite

9

-long. On August 7, 8, and 9, the computer shows my- presence at the ' '

station for days of 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br />,11 hours,: and 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />si respectively.

My memory failed me in that I did not recall that for each of these-long days I had ' numerous shoitter days which reduced my overall i average hours. ( Again, see Ebc.~ 1 ) .

One final correction'should-'also be noted. In Section!I'B, l

p. 3, I commented on a reduction'in radiation exposure. This was-

' based on my memory. Commonwealth : has advised me of certain inaccuracies in these comments. The exposure drop between.1976 and 1977 was only 484, not 624, and from 1974 through 1977 the exposure j rate had not exceeded 4 Rem, as I believed and stated.

Additionally, while not discussed in - my Answer, exposure rates - l

,1 returned to high levels for several years after 1977. This^was because of new work that had not been previously requirod.

Radiation exposure at high levels continued because of repair work 1 dor:o to tools and fuel handling equipment, ~especially the refuel' bridge, and because of other: work assignments. From 1985 through the present radiation expos = a rates again dropped dramatically when conhminated materials were discarded. 4 l

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~I Once again, my incorrect statements should have been subjected to critical vari.fication before filing my Answer. At this time all l I can do is set forth the actual facts as they have been brought ,

to my attention and offer my sincere apologies to the Commission for these inaccura,,les. I i

. Respectfully submitted,-  !

Robert L.-Dickharber i

STATE OF ILLINOIS ) i

) SS.

COUNTY OF ROCK ISLAND )

Robert L. Dickherber, bei.ug.first duly. sworn on oath, states that he has read the foregoing - statement- and that all factual  !

j statements made'in knowledge-and belief.. the same are true and correct to the best of his YsRoberthr L. Dickherber 4 ,

Signed and sworn to before me, a Notary Public, this 1st day of Junn, 1990. _

= :: ::n.s. m : :::

R HA Notsry Pubtle, S:sts of IIDnots

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Notary Wublic

; MyC m.n Egree Jan.10.1983 ' ; '

L ::::_ m .oa..,...s.~.:--^ -

Stuart R. Lefstein KATE, McANDREWS,-

BALCH, LEFSTEIN & FIENEGER, P.C. ,

Attorneys for Robert L. Dickberber 1705 Second Avenue, Suite'200 P.O. Box 3250 Rock Island, IL 61204-3250 Phone: 309/788-5661 l

7,.,

l UNITED STATES.

NUCLEAR REGULATORY COMMISSION IN THE MATTER OF: ) License No. SOP-2365-8  ;

R. L.-DICMERBER

). -Docket No. 55-5403 EA 90-031; j

) }

______.________._)  !

IN TEE MATTER OF )- 1

-) License Nos. DPR-29 & DPR-30: 1 COMMONWEALTH EDISON COMPANY ) Docket Nos. 50-254 & 50-256

-QUAD-CITIES: NUCLEAR POWER ) EA 90-032 STATION .)

_.1 EXEIBIT 1 TO SUPPLEMENTAL ANSWER OF _ ROBERT L. - DICFWD31L'R The following information, ' developed from' Commonwealth Edison's security computer, is set forth .to correct- -the misstatements appearing-in.my~ Answer:

)

The fuel outage occurred on or about September 10,-1989. I had been on vacation from September 1 through September 10. From September 11 through September 23 I was withh the computerJ access 1'

area every day, including two Saturdays and' .one Sundayj at an average of 10.8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> per : day with my longest day at 14. E hours.-

From September 24 through September 20 I had one Sunday off and my  !

I average hours within the protected area were 10,67 per day with my -

i longest day at 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />. From October 1 through October 17, which was the day of the incident, I had two Sundays off. My average hours in the protected area were 9.7 honrs with my longest day at q 4

16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br />.'

1 Also, and neces .;.rily, the computer shows that generally'my starting times were ne,mewhat later than initially stated and my

< exit' times were generally earlier than I had recalled and stated j

r in the Answer. Sometimes there is approximately a 5 minute wait

, 'to gain access.

.?

• ['

EMBIT 1 (CONTINUED) 1 j In the eight months prior to the fuel outage, the security -

computer shows my presence on the following weekends only: Sunday, February 19; Saturday, March 4; Saturday, March 11; Saturday, July.

15; Sunday, July 30; Saturday,. August 5; Sunday, August $; and a

Saturday, August 12. 'My presence is not-shown on any other weekend dates by the security computer during.those months, e The average daily hours of'my presence shown by the computer for the eight months prior to the. outage was approximately eight.

However, my average hours actually worked during those -months is  ;

necessarily higher, although undoubtedly less than what I stated.

The 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> average was arrived at by taking an avere;,. hours' per -i day for each of 32 weeks of 1989 through the' end of-Jugust,' except the week of May 1,2 as shown by the ' security compui er. . Certain weeks entering into this average contained- ' average . days substantially less than eight hours, suchlas 2, 4.3, 3.8, and 5.5..

These numbers contributed to bringing the average down to 8, 'as a

reported, t

However, it is high.ly probable that for most week days where l

the security computer showed me with.an: average of J.ess than eight '

I 1

I was on j ob assignments elsewhere performing at least _8 hours of I work for the entire day. - As an example, .during the ' summer of 1989,-. b o

I spent approximately.3 weeks in license requalification trasning.

outside of the protected area. These hours do not show -on the i-computer but are factored into the 8' hour daily average based only 2

I was in a management training prog am during that week outside of the protected area.

+

, . o.

EXEIBIT 1 (CONTINUED) },

on the computer.. Additionally, when I was taking this training I-would usually spend several hours at home in the evening study'ing, which, of course, is not contained in the average.

Besides taking training, other work was parformed outside.of the protected area. Dur1ng the fuel outage I wrote approximate".y.

five or- six different fuel handling procedures at heme.

- Commonwealth had never asked or suggested that I:do this _ woek at home but I did so-in _ order to get the job done.

Also, I have escorted on several occasions Commonwealth '

personnel to medical offices in Rockford for alcohol and drug.

t stating. A trip to Rockford from the Cordova- Station and back with waits at the medical offices averages approximately six hours, and I' probably was involved in such escorts during the eight month period prior to the incident approximately five times. I also had meetings with contractors witside of the station ,which are not shown on the computer records. I possibly. had such meetings approximately three or four times during the periods involved with a range of time from two to four hours.

Since there is no documentation for the precise number of -

hours worked outside the protected area in the eight months _ prior to the outage,- and based on the above information, it is reasonable -

to conclude that I was working an average of more than 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> per day but not 10 to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> par day as_ stated, nor was I regularly working 6-day weeks.

Finally, I was substantially mistaken regarding my recc11ection of holidays worked. In addition to Memorial Day and a

t v n

3; ,

EmBIT 1 (CONTIh m )_

Independence Day mentioned in my Answer, the computer shows me off on Ntv yea.r's Day, Lhcoln's Birthday, President's Day, Good Friday

-andLaborDay,whichfellduringmyvacaNon. A holiday for which I am shown present is Columbus Day.

I

. = .. = _ _ -

= ~~ ~= ~

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G-4_R S ^ L' 9 I Y "

EPeh .C=u ATES'10/20/0? PACE '

L i ,. 12116310 -

Eb-

.....i FOR T'ERSONS EXITING liETWEEN - 10/01/89; 00!00 AND 10/20/89 12812 1

• ! ! , . ')..  !

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___ _ __ __ _ _..____.._-___ _ ___ ___ __1.A _____ ______ ____ ____ ______ ____._ __i

• CeRP C AL P"a!. Pr" ST4TISM ?TeTIa9 EF"^"fE - _

NO, Ev2T TI"r C ' '"" - "

NANE . NUMBER . DEPT DATE TIME-DATE TIME SPENT LATIVE .

01856 DICK 1tERDER ROBER 128

, A f B Et 1 h Y PL'EJrD urD D M D t* D AOn -

FUEL rhag.g o l 10/02/89 06820.10/02/89 15127 9106333 90 4.

4AInIIDO A A 4 Set 4 A / A'I Inn i1#BA e9AA94A 4 L" . .. . A I "A % ' ,

f. hIB5I DICKlfdRhkR.RbbkR I2b FbEl Ib/h4/09 bII27 Ib/h4/09 I6545 10113555 :593655U2 01?56 SICErR*" ROSER 12e rLaEL' is/05/9= ei!?2 10/e5/e? 15!5!

a!!?!!?

01856 DICKHERDER ROBER 128  ??!2'!'!? -

FUEL. 10/06/99 06131 10/06/09 15333 9301140 47!26107-l As95g gycengtppgo onggp igg .rygt 39f97 ego ng 9 A. - i9f97ean 35 gig gg73747 5535795 p j .

l. 01856 DICKlfERBER RDBER 128 FUEL? 10/69/99 06133 10/09/89 15!05:

01a56 P!Pruros,go oggge ggo c ygi_ yaf.9foo ag9p gnf,9fg. g7;g7 8132845 3935tgan 6413013$ h  !

01856 DICKHERDER ROBER 7.cggge75 -

n 128 FUEL 10/11/89'06136 10/11/89 16215 9339302 J L, c_ een53 nyruurns.Ep onaro- igg rurs 85300137 infigfgo agtyg infigfoo syrig sn t mon g r o5eantna l 01856 DICKilERBER ROBER 129 FUEL 10/13/99.06I36 10/13/89 15135 8159812 104 t(39116 inningt44- (

nin51 purutarongo onngo 7,9 ent s_ p i-sn/na/no ngsto 19fea/go notag- 3tg7t3a 1 01956 DICKHERBER ROBER 128 FUEL 10/14/89 2213'-10/15/89'14850' p 46!13148 124816137i k,

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na

-nsn53 nicruronro onneo  ! in curi_ i tafezfoo azegn gneigfgo 4oegn s o n ico e g g s r s t i 5 f g, f 01856 DICKilERDER ROBER, 128

j g asg53 pyrvurongs> nnns o FUEL 10/17/B9.068I/f 10/17/89 14856 8139334 145 t 55 t 2744-- @

i

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_ inina/no azes'y ineinfgo 13eng oeacgtan 15=y a n a 77 I 01056 DICKHERBER ROBER 128. FUEL I

k 10/19/89 04 32 10/19/99 15117 8845!03 164833810tk,;*

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