ML103010233
| ML103010233 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 10/26/2010 |
| From: | Taggart M - No Known Affiliation |
| To: | NRC/SECY/RAS |
| SECY RAS | |
| References | |
| 75FR65249 00001, NRC-2010-0304, PRM-26-5 | |
| Download: ML103010233 (4) | |
Text
Page 1 of 2 PRM-26-5 (75FR65249)
As of: October 27, 2014 Received: October 26, Status: Pending-Post PUBLIC SUBMISSION Tracking No. 80b7822 Comments Due: Janua ISubmission Type: We Docket: NRC-2010-0304 Nuclear Energy Institute - Fitness-for-Duty Programs Comment On: NRC-2010-0304-0001 Anthony R. Pietrangelo on Behalf of the Nuclear Energy Institute; Receipt of Petition for Rulemaking I
0 2010 f
rWy 05, 2011 b
Document: NRC-2010-0304-DRAFT-0002 Comment on FR Doc # 2010-26715 DOCKETED USNRC October 27, 2010 (4:00pm)
OFFICE OF SECRETARY RUILEMAKINGS AND Submitter Information ADJUDICATIONS STAFF Name: Mitchel Taggart Address:
225 Bartley Ln Fulton, MO, 65251 Submitter's Representative: None Organization: None General Comment I am a licensed SRO at Callaway Nuclear Plant. I am submitting these comments as an individual licensed operator and not on behalf of the Callaway Station.
I support the NEI proposal. The MDO portion of the rule change for Part 26 Subpart I has been an administrative overload to implement.
Callaway had a supervisor violate the MDO when he was called in for a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> meeting on a short notice. When he put his hours worked in the computer tracking system he realized that this 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> meeting resulted in a violation. The MDO calculation is too complicated for an individual to track without the aid of a computer program.
Another situation involved working more overtime by working a shortened day in a strategic time during the work cycle allowed individuals at least two more 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> shifts of overtime and one individual three days of additional 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> shifts. This was acceptable per the MDO and each of these individuals worked in excess of the 54 hour6.25e-4 days <br />0.015 hours <br />8.928571e-5 weeks <br />2.0547e-5 months <br /> average for the work cycle.
Both of these examples demonstrate a flaw with the MDO portion of the Work Hour limitations. One demonstrated the complexity of implementation mandating the use of a computer program for implementation.
The other showed, with strategic work hour manipulation, a large amount of overtime can still be worked. I heard one person say they feel they are actually getting more overtime now than before the rule change.
Again, I support the recommended change to simplify the implementation so a computer program is not required to verify compliance and a stricter review of the 54 hour6.25e-4 days <br />0.015 hours <br />8.928571e-5 weeks <br />2.0547e-5 months <br /> average to curb abuse.
https://fdms~erulemaking.net/fdms-web-agency/component/submitterlnfoCoverPage.Call=Print&Printld...
10/27/2010
Page 2 of 2 https://fdms.erulemaking.net/fdms-web-agency/component/submitterInfoCoverPage?Call=Print&Printld...
10/27/2010
Rulemaking Comments
'From:
Sent:
To:
Subject:
Attachments:
Gallagher, Carol Wednesday, October 27, 2010 11:29 AM Rulemaking Comments Comment on PRM-26-5 NRC-2010-0304-DRAFT-0002.pdf
- Van, Attached for docketing is a comment on PRM-26-5 (75 FR 65249) that I received via the regulations.gov website on October 26, 2010.
- Thanks, Carol 1
Received: from HQCLSTR01.nrc.gov ([148.184.44.76]) by TWMS01.nrc.gov
([148.184.200.145]) with mapi; Wed, 27 Oct 2010 11:29:07 -0400 Content-Type: application/ms-tnef; name="winmail.dat" Content-Transfer-Encoding: binary From: "Gallagher, Carol" <Carol.Gallagher@nrc.gov>
To: Rulemaking Comments <Rulemaking.Comments@nrc.gov>
Date: Wed, 27 Oct 2010 11:29:09 -0400
Subject:
Comment on PRM-26-5 Thread-Topic: Comment on PRM-26-5 Thread-Index: Act167NMCajeJPr4QCuSbJaKjbOotg==
Message-ID:
<6F9E3C9DCAB9E448AAA49B8772A448C5469C 192421 @HQCLSTR01.nrc.gov>
Accept-Language; en-US Content-Language: en-US X-MS-Has-Attach: yes X-MS-Exchange-Organization-SCL: -1 X-MS-TNEF-Correlator:
<6F9E3C9DCAB9E448AAA49B8772A448C5469C 192421 @HQCLSTRO1.nrc.gov>
MIME-Version: 1.0