ML13330A440

Forwards Request for Addl Info Re Proposed Change 119 to Tech Specs Concerning Working Hour Limitations.Response Requested within 30 Days

ML13330A440
Person / Time
Site:	San Onofre
Issue date:	09/05/1984
From:	Paulson W Office of Nuclear Reactor Regulation
To:	Baskin K Southern California Edison Co
References
TAC-54127 LSO5-84-09-002, LSO5-84-9-2, LSO5-84-9-22, NUDOCS 8409060258
Download: ML13330A440 (3)

Text

September 5, 1984 Docket No. 50-206 DISTRIBUTION LS05-84-09-002 Docket PM NRC PDR 0ELD Local PDR ELJordan ORB Reading JNGrace Mr. Kenneth P. Baskin, Vice President NSIC ACRS (10)

Nuclear Engineering WPaulson SEPB Licensing and Safety Department CJamerson Souther California Edison Company 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770

SUBJECT:

PROPOSED CHANGE NO. 119 TO THE TECHNICAL SPECIFICATIONS Re:

San Onofre Nuclear Generating Station, Unit No. 1 By letter dated May 17, 1984, you forwarded Proposed Change No. 119 to the San Onofre, Unit No. 1 Technical Specifications. In reviewing your submittal, we find we need the additional information listed in the enclosure. It is requested this information be submitted to this office, with a copy to the NRC Region V Office* within 30 days of receipt of this letter.

The reporting and/or recordkeeping requirements contained in this letter affect fewer than ten respondents; therefore, OMB clearance is not required under P.L.96-511.

Sincerely, Original signed by Walter A. Paulson, Acting Chief Operating Reactor Branch #5 Division of Licensing

Enclosure:

As stated cc w/enclosure:

See next page.

• U.S. Nuclear Regulatory Commission 1450 Maria Lane, Suite 210 Walnut Creek, CA.94596 ATTN: G. B. Zwetzig DL:RB#5 DL

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DL:- B45 CJamerson *b EMcKenna\\

WPaulson

//84

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/4/84 8K 0 500020D PDR ADO I

-PDR

Mr. Kenneth September 5, 1984 cc Charles R. Kocher, Assistant General Counsel James Beoletto, Esquire Southern California Edison Company Post Office Box 800 Rosemead, California 91770 David R. Pigott Orrick, Herrington & Sutcliffe 600 Montogmery Street San Francisco, California 94111 Dr. Lou Bernath San Diego Gas & Electric Company P. 0. Box 1831 San Diego, California 92112 Resident Inspector/San Onofre NPS c/o U.S. NRC P. 0. Box 4329 San Clemente, California 92672 Mayor City of San Clemente San Clemente, California 92672 Chairman Board of Supervisors County of San Diego San Diego, California 92101 Director Energy Facilities Siting Division Energy Resources Conservation &

Development Commission 1516 - 9th Street Sacramento, CA 95814 U.S. Environmental Protection Agency Region IX Office ATTN:

Regional Radiation Representative 215 Freemont Street San Francisco, California 94105 John B. Martin, Regional Administrator Nuclear Regulatory Commission, Region V 1450 Maria Lane Walnut Creek, California 94596

Enclosure San Onofre Nuclear Generating Station -

Unit 1 Working Hour Limitations Docket No. 50-206 The Commission policy regarding the use of overtime is defined in Technical, Specification 6.2.2f for San Onofre Unit 3. Your submittal attempts to clarify a number of the subjective elements of that policy. Although we find certain of these clarifications acceptable, others appear to go beyond the intent of the Commission policy, as indicated below. Therefore, please revise your submittal as necessary to address these concerns:

1. You have proposed to define "heavy overtime" as "greater than 25%." By such a definition, work schedules of up to 50 hours5.787037e-4 days <br />0.0139 hours <br />8.267196e-5 weeks <br />1.9025e-5 months <br /> per week could be routinely scheduled. In view of the Commission's goal of an "8-hour day, 40 hour4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> week while the plant is operating," we find such routine use of overtime at this level inconsistent with conscientious efforts to meet the goal.

We believe the goal should be zero overtime when the plant is operating and that any individual overtime in excess of 10% per week should be considered "heavy".

2. You have proposed that first line supervision be authorized to determine whether plant conditions constitute "unforeseen problems" for the purpose of-applying the overtime guidelines. We believe this is not sufficiently high in the management structure to provide the perspective necessary for such a decision. We believe such a determination should be made by the Station Manager, Deputy Station Manager or Operations Manager.

3. If we understand your proposal correctly, you intend that time spent consuming food (meal time) is not to be included when calculating a work period, but, rather, is to be counted as part of the break time. While this is appropriate when one considers a normal eight hour shift, we do not consider it appropriate when significant overtime is involved. In the latter case, we consider it important that individuals have a minimum break period of at least eight hours. Your proposal would further reduce the length of the break by taking credit for meal times(s) occurring during the work period. In such a case, the break period could be reduced to as little as six hours.

In view of commuting time requirements, we consider such a break period inadequate to assure reasonable rest and alertness.

We also find the inclusion of meal time(s) in the break period an unjustified extension of the Commission's policy.