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:
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