ML052430220

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Comment (3) Submitted by D. M. Jurss on Proposed Rule PR-26, Fitness for Duty Programs
ML052430220
Person / Time
Site: Point Beach  NextEra Energy icon.png
Issue date: 08/30/2005
From: Jurss D
- No Known Affiliation
To:
NRC/SECY/RAS
Ngbea E S
References
70FR50442 00003, FOIA/PA-2006-0113, PR-26
Download: ML052430220 (4)


Text

USNRC August 30, 2005 (4:39pm)

-- From: "Brendam <bbkkjur@lakefield.net> OFFICE OF SECRETARY To: <fitnessforduty@ nrc.gov> RULEMAKINGS AND Date: Tue, Aug 30, 2005 10:52 AM ADJUDICATIONS STAFF

Subject:

PBNP schedule Rebecca, I read the federal register Aug 26 for fitness for duty (Vol. 70, No.165). Page 50589 describes work hour scheduling 26.199(c). If I am reading the verbiage correctly; it seems as though my concern with Point Beach's eight-hour shift schedule violating 26.199(d) work hour controls for individuals is unfounded. My concern was the normal shift schedule at Point Beach includes two periods of working 7 consecutive days in a row during the evening and night shift of the schedule. 26.199(d)(2)(ii) requires a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> break in any seven day period, which in my earlier E-mails and conversations appeared to be inconsistent with Point Beach's schedule.

The federal register states: "The maximum work hour and minimum break requirements that are specified in proposed 26.199(d) [work hour controls for individuals] would be intended for infrequent, temporary circumstances, and not as guidelines or limits for routine scheduling." If I am reading this correctly Point beach's schedule need to meet 26.199(c) "in a manner that is consistent with the objective of preventing impairment from fatigue due to the duration, frequency, or sequencing of successive shifts." I believe our schedule meets those objectives, and I suppose that will need to be reviewed by someone from the NRC.

I would like to thank you for the time and effort you have devoted to assisting me with this matter.

Sincerely, D.M. Jurss CC: <ddmmjur@ lakefield.net>

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___ _seLA-i 0(01 SECi1 -0 D,

CY - Fwd: PBNP schedule Page 1 I From: Rebecca Karas To: Ngbea, Evangeline Date: Tue, Aug 30, 2005 3:54 PM

Subject:

Fwd: PBNP schedule Please docket the attached email as a comment on the Part 26 proposed rule.

CC: Desaulniers, David; Gallagher, Carol; McCune, Timothy Persensky, Julius

emp\UW)00001.TMP Page 1 1 erp(W}O0 .TM . P.g 1 Mail Envelope Properties (4314B971.80D1 24: 456)

Subject:

Fwd: PBNP schedule Creation Date: 8/30/05 3:54PM From: Rebecca Karas Created By: RLK@nrc.gov Recipients nrc.gov OWGWPO0 1.HQGWDO01 DRD CC (David Desaulniers) nrc.gov owf5_po.OWFN_DO ESN (Evangeline Ngbea) nrc.gov twf2_po.TWFN_DO TSM5 CC (Timothy McCune) nrc.gov twf4_po.TWFNDO CAG CC (Carol Gallagher) nrc.gov twf5_po.TWFN_DO JJP2 CC (Julius Persensky)

Post Office Route OWGWPO01 .HQGWDO01 nrc.gov owf5_po.OWFNDO nrc.gov twf2_po.TWFN_DO nrc.gov twf4_po.TWFNDO nrc.gov twf5_po.TWFN_DO nrc.gov Files Size Date & Time MESSAGE 418 08/30/05 03:54PM Mail Options Expiration Date: None Priority: Standard Reply Requested: No Return Notification: None

emp\GWO00001 .TMP Page 2 1 Concealed

Subject:

No Security: Standard