ML20206U326
| ML20206U326 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 03/29/1999 |
| From: | Grobe J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Kingsley O COMMONWEALTH EDISON CO. |
| Shared Package | |
| ML20206U278 | List: |
| References | |
| NUDOCS 9905250168 | |
| Download: ML20206U326 (6) | |
Text
05 24/99 17:14 FAX 630 515 1078 l'.S.NRC REGION 111 goj t
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usLE. lu !Nols 00532-4351 March 29, 1999 Mr. Oliver D. Kingsley President, Nuclear Generation Group Commonwealth Edison Company ATTN: Regulatory Services Executive Towers West lli 1400 Opus Place, Suite 500 Downers Grove,IL 60515
SUBJECT:
BYRON STATION OVERTIME
Dear Mr. Kingsley:
The Nuclear Regulatory Commission (NRC) Region ill staff conducted a review of your response dated December 8,1998, and supplemental response dated December 22,1998, to our letter dated October 30,1998, concerning the use of overtime in the Byron Station operations department. The NRC staff discussed the results of this review with Mr. W. Levis, Byron Station Manager, during a telephone conference call on February 16,1998.
The NRC staff determined that additionalinformation, desenbed in the enclosure, is necessary to adequately evaluate this matter. We request that this additional information be submitted within 30 days of the date of this letter. Your response should not be docketed, and should be sent in an envelope addressed to the Region M! '~nforcement/ Investigations Officer.
We also request that your response contain no personal privacy, proprietary, or safeguards information. If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such material, you mLLs.t specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g. explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR2.790(b) to support a request for withholding confidential commercial or financialinformation.) If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21, The enclosure to this letter should be controlled and distribution should be limited to personnel with a "need to know" until your evaluation has been completed and reviewed by NRC Region lli personnel. The enclosure to this letter is considered *NOT FOR PUBLIC DISCLOSURE."
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05/24/99 17:15 FAX 630 515 1078 U.S..NRC REGION III
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We appreciate your cooperation and will gladly discuss any questions you rnay have concerning this information.
Sincerely, b[
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[vJohn A. Grobe, Director DMslori of Reactor Safety
Enclosure:
Details (NOT FOR PUBLIC DISCLOSURE) cc w/ encl: W. Levis, Site Vice President l
1
05 24/99 17:15 FAX 630 515 1078 l'.S.SRC REGION 111 goi3 NOT FOR PUBLIC DISCLOSURE ENCLOSURE Please reference tracking number 98-A-0165 in your response.
q DETAILS Technical Specification 6.2.2.e states that the amount of overtime worked by facility 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 /> week during plant operation; however, during unusual circumstances, and on a 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 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
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other independent reviews that overtime usage had not adversely impacted operation of the
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Byron Station.
j 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 I
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 overtime 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 your response. Explain what actions you have taken to determine the extent and safety impact of individuals with much higher than average overtime especially during peak usage times and your conclusions in this area.
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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0.U24/99' 17:15 FAX 630 515 1078 L'.S.NRC REGION III
@ota March 29, 1999 j
i Mr. Oliver D. Kingsley President, Nuclear Generation Group Commonwealth Edison Company ATTN: Regulatory Services Executive Towers West 111 1400 Opus Place, Suite 500 i
Downers Grove,IL 60515
SUBJECT:
BYRON STATION OVERTIME
Dear Mr. Kingsley:
The Nuclear Regulatory Commission (NRC) Region 111 staff conducted a review of your response dated December 8,1998, and supplemental response dated December 22,1998, to our letter dated October 30,'1998, conceming the use of overtime in the Byron Station operations department. The NRC staff discussed the results of this review with Mr. W. Levis, Byron Station Manager, during a telephone conference call on February 16,1998.
The NRC staff determined that additional information, described in the enclosure, is necessary to adequately evaluate this matter. We request that this additional information be submitted within 30 days of the date of this letter. Your response should not be docketed, and should be l
sent in an envelope addressed to the Region !!! Enforcement / Investigations Officer, We also request that your response contain no personal privacy, proprietary, or safeguards information. If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such material, you muf.t specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g. explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by,10 CFR2.790(b) to support a request for withholding confidential commercial or financial information.) If safeguards information is necessary to provide an acceptable response, please provide the level of protection described he e ci su to this letter should be controlled and distribution should be limited to personnel with a "need to know" until your evaluation has been completed and reviewed by NRC Region ill personnel. The enclosure to this letter is considered *NOT FOR PUBLIC DISCLOSURE."
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05/24/90 17:16 FAX 630 515 1078 U.S..NRC REGION III r O15 d
O. Kingsley We appreciate your cooperation and will gladly discuss any questions you may have conceming this information, Sincerely, Original signed by Steven Reynolds John A. Grobe, Director Division of Reactor Safety
Enclosure:
Details (NOT FOR PUBLIC DISCLOSURE) cc w/ encl: W. Levis, Site Vice President bec w/ encl: AMS File No. Rill-98-A-0165 AMS File No. Rill-99-A-0034
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o.nTamrTnar FH MF5EFW m LL.5..%Ec E GION 111 4oi6 O. Kingsley We appreciate your cooperation and will gladly discuss any questions you may have concerning this information.
Sincerely, 1
John A. Grobe, Director Division of Reactor Safety
Enclosure:
Details (NOT FORpBBO-disci.050RQ cc w/ encl: K. Graesser, Site Vice President bec w/ enci: AMS File No. Rlil-98-A-0165 AMS File No. R!ll-99-A-0034 DOCUMENT NAME: G:\\EICS\\AMS-LTRS\\98-A-165.l21
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