ML19327B770

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Responds to Conveying Continuing Concerns of Hl Nickerson Re Overtime Worked by Personnel Operating Nuclear Power Plants
ML19327B770
Person / Time
Issue date: 11/01/1989
From: Taylor J
NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To: Hastert J
HOUSE OF REP.
Shared Package
ML19324C022 List:
References
FRN-47FR23836, RULE-PR-50 CCS, NUDOCS 8911130170
Download: ML19327B770 (3)


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' UNITED STATES i

- E NUCLEAR REGULATORY COMMISSION l

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4 November 1,1989 S

l The Honorable J. Dennis Hastert United States Member,f Representatives House o 100 Lafayette Street L

^0ttawa, Illinois 61350

Dear Congressman Hastert:

1 I am responding to a letter which you forwarded to us on October 11, 1989.

The letter conveyed the continuing concerns of Mr. H. L. Nickerson about overtime worked by personnel operating nuclear' power pl6nts. As Mr. Nickerson's letter indicated, the specific cases Mr. Nickerson cited were investigated by Lour Region III office and a' copy of the report was sent to him.

The current NRC policy statement entitled " Policy on Factors Causing Fatigue i

t 1Y of 0,wratir.g Personnel at Nuclear Reactors" is enclosed for your information i

and assistance in responding to Mr..Nickerson. The policy was issued in 1

1982. Prior to issuance, a draft of the policy was published for public 4

consnent' ano the input the agency received was taken into account in' 1

- fonnulating the version now in effect.

Since issuance, the NRC, in its I

' continuing review of nuclear power plant operations, has not observed significant safety concerns relating to the amount of overtine worked by 1

personnel performing safety related functions.

l e

In the course of its normal review of policies and technical positions s

against new information and results of relevant research, the NRC.is continuing to study the subject of overtime and its relationship to risk. He d

will take Mr. Nickerson's views into account 'as a part of our review.

j Please let me know if we can be of any further assistance.

Sincerely, c

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Jimes M. T or t-cting Executive Director i

for Operations

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Enclosure:

As stated K

FUU. TEXT ASCll SCAN A"

0CD gq l(l~DolI p 2.

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y Federal Regleter / Vol. 47. N2.10 / Tuesday June 1.1985 / Nitioue 33030' Per the Appeal heard.

normal g.hoor day.40. hour week whDe radioactive waste disposal facility C.)ese ghoemaker, the plant le operaties. However, in the located at snelung, South Carollr a.De t

sec,eaery se the AmpeelAserd, etont that unforeseen problems require beels for this Memorandum of substantial amotante of overtime to be Agreement are two fold:(1)De Offloo j

pee.. m myege

e. w used, or during extended periode of of the Ruocutive legal DIroctor. NRC, l

enime sees nie.e,.o i

shutdown for refueling, major recently determined that information maintenance or major plant gathered by South Carchna State thselear power Plant Staff Wertilng modiAcetions, on a temporary basis, the laspectore can be need by the NRC in i

j Moure.

fouowing guidelines shall be fouowed:

enforcement notions against NRC

a. An inalvidual abould niot be-licensees: (2) Pursuant to the previolone Assasov: Nuclear Regulatory permitted to work more thea ts hours of the South Carolina Radioactive Commlwi'"'

straight (excluding shift turnover time).

Weste Transportation and Disposal Act

&cT*osa publication of revised polioY

b. An todividual should not be of 1900. (Act No.439), the State

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resa ear power plant staff permitted to work more thaa lg hours la enhanced control over the shipment of w:rkins any M. hour period, not more than M radioactive waste into and within the hours in any to hour period nor mare State, and intenstBed its enforcement ausseeasm On February 11. test, the than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in any seven day period scuona.

Nuclear Regulatory Comedulon I*$,

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Post Puemean eespostenafe00s coeffacT:

pubitched a " Policy on Factors Causing Fetique of Operating personnel at abould be allow.ed between work Rovert E. Trojanowski, Regional State t i Nuclear Reactore." 47 FR 7381 periode (includlag ahlft turnover t ne).

Unison OfBoer. Telephone 404-221-Commente received since publication

d. Exce I during extended shutoown 6597. U.S. Nuc4ar Regulatory Comminion. RD.101 Morietta St., N.W.,

have revealed questions concerning the periode, t e use of overtime should be pulley etotement. Accordingly, the conaldered on an individual beste and Suite 3100. Atlanta Georgia 30300.

policy statement has been revloed and not for b enure staN on a ehlft.

Dated at Atlanta, Georgia thit 17th day the revised version la reproduced below.

Recognising that very unusual of May legs.

Changes include:(1 De addition of a circumstanose may arise requiring For the Nualear Reguletory Comunklon.

j eentence which exp citly states that the deviation from the above guidelines.

3

, p* oqtesg *y objective of the working hour policy is such deviation shall be authorised by to have operating personnel work an S.

the plant manager or his deputy, or hour day. 40. hour week: (2) De addition higher levels of management.ne' Memorandum of Agreement Between of a phrase to indicate that the stated paremount consideration in such the U.S. Nuclear Regulatory thl=too w:rking hour restrictions are applicable author'.setion shall be that algn16 cant and the 8.C. Department er Health and during extended periods of shutdown for reductions in the effectiveness of Environmental Centrol. Related to the refueling, malor maltenance or major operating personnel would be highly Use of %Ard Party Data and the

' cddition of a phrase exempting in addition, procedures are Radioactive Weste to the Rarew' ell-;of plant modificatione: and (3)he unlikely.

Regulation of NRC 1.L-cutended shutdown periods from the encouraged that would allow licensed Fadlity; Background requirements to consider use of overtime operetore at the controls to be no Chem Nuclear Systems. Inc.

. only on en individual basis.

periodically relieved and awlgned to (CNSI) low level redioactive waste Policy os Facters Causing Fatigue of other dutfee away from the control disposal facility located at Snelling.

,Operstias Personnel at Nuclear Reactom board during their tour of duty.

South Carolina. has been in operetion Pon ruimen esponesavices cowfact:

eince 1971. Both the U.S: Nuclear 1.lcensees of opere'ing plants and Mr.14wnnos P. Crockw. (301) 657. Regulatory Conuniasion (NRC) and the applicants for operating licenue shall establish controls to prevent altuations Deled at Betbuda Marylan't, this 25th day S.C. Department of Health and where tatigue could reduce the ability of of May, tent.

Environmental Control (DHEC) beve operating personnel to keep the reactor For the Nuclear Reguletory Commlesion.

responsibilities for the reguletion of in e esfe condition.he controle obould lobe A.Ewelleeld.

NRC licensees who ship radioactive focus on ehlft staffing and the use of Actmp Chief. Llamsee Quellficatione #ronch, weste to the disposal facility. NRC's cvertime-key job reisted factors that D/riston of#uman Fbesors Sofety.

regulatory authority is derived from the influence fatigue.

ye oss m.msiruns wwa ses em; Atomic Energy Act of1954, se amended.

De objective of the controle would be enAme sees rees.ews the Energy Reorganisation Act of 1974, 13 assure that, to the extent practicable, as amended, and the regulations.

implementing these Acts contained in 10 personnel are not assigned to ehlft Sousi Caroline Department of MeeMh Cl? 71.5. South Carolina, an agreement duties while in a fatigued condition that and EnWonmental Control and the State, derives its regulatory authority could significantly reduce their mental Nucieer Regulatory Commiselon; from the applicable State regulatione ciertness or their decision making Memorandum of Agreement Related to which are compatible with the Federal espebility.The controls shall apply to Use of Third party Data and Regulataan regulations cited above.

the plant staff who perform safety.

of NRC Woensee shippers of CNSI opwations are regulated under related functions (e.g., senior reactor Radioactive Weste to the Samwell both a South Caroline agreement State cperators. reactor operators, health phyelcists, auxillery operators, and key Facility license and an NRC license which sisintenance personnel).

The Memorandum of Agreement authorir.ee the receipt and burial of Enough plant operating personnel published below describes the special nuclear meterial(SNM)in should be employed to maintain cooperative regulatory policy being quantities greater than authortred under adequate ehtft coverage without routine implemented by the NRC and the State State jurisdiction. Both DHEC and the heavy use of overtime.ne objective le of South Caroline with regard to NRC conduct routine periodic inspection 13 have operating personnel work a enforcement activities et the low level for those por'.lons of ette operations e-M m

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Distribution:

Central File WRegan L.

. 1 November.1,1989 TMurley EDO 4825 JSniezek ED0 r/f r

a The Honorable J. Dennis Hastert.

g,

Y89-1123 Mes6er, United States DCrutchfield CPaperiello House of Representatives pggj),3pg, i

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100 Lafayette Street DMossburg-4825 Ottawa,' Illinois 61350 JRoe Dsar Congressman Hastert:

%an L

I am responding to a letter which you forwarced to us on October 11, 1989.

The letter conveyed the continuing concerns of Mr. H. L. Nickerson about

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. overtime worked by personnel operating nuclear power plants. As Mr. Nickerson's-letter indicated, the specific cases Mr. Nickerson cited were investigated by our Region III office and a copy of the report was sent to him.

The current NRC policy statement entitled " Policy on Factors Causing Fatigue 1

of Operating Personnel at Nuclear Reactors" is enclosed for your information and assistance in responding to Mr. Nickerson..The policy was issued in 1982. Prior to issuance, a-draft of the policy was published for public-l

comment and the input the agency received was taken into account in formulating the version now in effect. Since issuance the NRC, in its 1

continuing review of nuclear: power plant operations,. has not observed significant safety concerns relating to the amount of evertime worked by personnel performing safety related functions.

L In the course of its normal review of policies and technical positions against new information and results of relevant research, the NRC is continuing to study the subject of overtime and Its relationship to risk. We

+

will take Mr. Nickerson's views into account as e part of our review.

Please let me know if we can be of any further assistance.

Sincerely.

Original Signed By:

James M. Taylor James M. Taylor Acting Executive Director P

for Operations

Enclosure:

As stated

+

"Thf2cortspondenceaddressespolicyissuespreMouslyresolvecbythe Codmiksfon nsmits factualsinformation, or restatepConsnission policy."

ADT:NRR*

FMiraglia 10/26/89

  • See Previous Concurrences

.e 'b. b Document-Name: GREEN TICKET 4825

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