ML13316A808
| ML13316A808 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 03/06/1985 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML13316A804 | List: |
| References | |
| TAC-54127, TAC-54700, TAC-54701, NUDOCS 8503140228 | |
| Download: ML13316A808 (4) | |
Text
UNITED STATES
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NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION SUPPORTING AMENDMENT NO.
88 TO PROVISIONAL OPE-RATING LICENSE NO. DPR-13 SOUTHERN CALIFORNIA EDISON COMPANY SAN ONOFRE NUCLEAR GENERATING STATION, UNIT NO. 1 DOCKET NO. 50-206
1.0 INTRODUCTION
By letter dated July 17, 1984, as modified and supplemented on November 30, 1984, Southern California Edison Company (the licensee) proposed changes to the Technical Specifications for San Onofre Nuclear Generating Station, Unit No. 1. These changes add administrative guidance and requirements relating to assignment of overtime to personnel performing safety-related act.ivities.
A Notice of Consideration of Issuance of Amendment to License and Prooosed No Significant Hazards Consideration Determination and Opportunity for Hearing related to the requested action was published in the Federal Register on January 23, 1985 (50 FR 3055).
No comments or requests for hearing were received.
2.0 DISCUSSION By letter dated February 8, 1982 (Generic Letter 82-02), the NRC forwarded a Commission policy statement on factors causing fatigue of operating personnel at nuclear reactors to all licensees of operating nuclear power plants, applicants for operating license and holders of construction permits.
Generic Letter 82-12, dated June 15, 1982, transmitted a revised version of the policy statement.
In Generic Letter 82-16 (dated September 20, 1982), the Commission identified certain items in NUREG-0737, "Clarification of TMI Action Plan Requirements," for which technical specifications (TS) were required. One of these was that portion of NUREG-0737 item I.A.1.3,.dealing with limits on the use of overtime. The generic letter provided Model Technical Specifications (MTS) for1this item and requested licensees to review their present facility TS to determine if they were consistent with the MTS.
Where there was a deviation or an absence of a specification, licensees were requested to submit an application for license amendment.
PDR3A 00206 PDR
Generic Letter 83-14, dated March 7, 1983, provided clarification of the previous guidance in this area by.defining the "key maintenance personnel" subject to the Commissioh's policy.
By letter dated Julv 17, 1984, the licensee responded to the request contained in Generic Letter 82-16 regarding overtime limits.by submittinq proposed TS. The licensee's letter of November 30, 1984, revised and clarified the earlier submittal.
3.0 EVALUATION The NRC staff compared the licensee's proposed TS with the MTS on overtime limits presented in Generic Letter 82-16, and the additional guidance contained in Generic Letters 82-02 and 82-12 (NRC policy on overtime) and 83-14 (definition of key maintenance personnel). The staff's evaluation is discussed in the following paragraphs.
A. Job Coverage The MTS provided by Generic Letter 82-16 specify that the overtime limits are to apply to the "unit staff who perform safety-related functions, e.g., senior reactor operators, health physicists, auxiliary operators, and key maintenance personnel."
Generic Letter 83-14 defines key maintenance personnel as those "responsible for the correct performance of maintenance, repair, modification or calibration of safety-related structures, systems or components, and who are personnel performina or immediately supervising the performance of such activities."
The licensee's proposed TS specifically define the job.classifications subject to overtime limitations. These include licensed operators, auxiliary operators, health physicists, electricians, instrumentation and control technicians, computer technicians, machinists, boiler mechanics, contractor personnel, etc. - and their first line supervisors.
Based on the review of the job coverage proposed by the licensee, the staff concludes that the proposed TS conform to the applicable guidance.
B. Guidelines The guidelines proposed by the licensee differ in some respects from those set forth in the MTS. In general, however, the principal difference lies in the licensee's attempt to explicitly define applicable conditions.
For example, where the MTS refer to "while the plant is operating," the licensee proposes to define this b%
parenthetically adding "(Modes 1, 2, 3, and 4)."
Similarly, the licensee proposes to define "substantial amounts of overtime" as 25 percent, and defines "unforeseen problems" as forced shutdowns, equipment failure, unscheduled repair, entry into an ACTION statement, etc. The staff has reviewed these rroposed definitions and conclude they are consistent with regulatory guidance and, therefore, are acceptable.
- 3 The other difference proposed by the licensee is consideration of "meal time" in the calculation of hours worked and hours of break.
As used by the licensee, the term "meal time" can have two meanings.
When used in the context of normal working hours, the expression "ieal time" has its conventional meaning - a break occurring durina the normal work period when employees are relieved of their work.
responsibilities. When used in the context of overtime,."meal time" means time earned in addition to that actually worked for which (under existing policy and/or contractual agreements) the employee shall be paid.
For example, a licensee's representative stated the agreement provides that the employee shall earn one-half hour of "meal time" for each two hours worked. In such a case, the employee would not only be paid for two hours of overtime, but also for one-half hour of "meal time."
The employee would not be reouired to eat during this period, nor even remain on site. This "meal time," therefore, is recorded only for overtime pay purposes.
The licensee addresses these differences by stating that the time spent as "meal time" during normal work periods will not be included when cal.c.ulating the hours worked or the break period. On the other hand, the licensee states that time recorded and paid as "meal time" when working overtime hours, will not be included when calculating hours worked but will be included when calculating the break period available to the eimolovee.
Because this paid "meal time" is earned in the course of working overtime, and does not subsequently require the employee's presence on site, the staff finds the licensee's proposed method for accounting for this time acceptable.
Regarding the specific overtime guidelines proposed by the licensee, these conform to the guidance provided in the MTS except for added notes relating to "meal time". These notes clarify how the licensee will apply "meal time" hours in calculating work periods and breaks, and are consistent with the discussion in the preceding paragraph.
In addition, this review indicates the guidelines are consistent with the Commission policy set forth in Generic Letter 82-16. The staff, therefore, concludes the proposed specific guidelines are acceptable.
4.0 ENVIRONMENTAL QUALIFICATION This amendment relates to changes in recordkeeping, reporting, or administrative procedures or requirements. Accordingly, this amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.2?(c)(10). Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of this amendment.
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5.0 CONCLUSION
The staff has concluded, based on the considerations discussed above, that:
(1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, and (2) such activities will be conducted in compliance with the Commission's regulations and the issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public.
6.0 ACKNOWLEDGEMENT This Safety Evaluation has been prepared by G. Zwetzig.
Dated:
March 6. 1985