ML19327B781

Responds to Re Hl Nickerson Concerns Re Overtime Worked by Personnel Operating Nuclear Power Plants.Nrc Continuing to Study Subj of Overtime & Relationship to Risk. Views of Others to Be Taken Into Account During NRC Review

ML19327B781
Person / Time
Issue date:	11/01/1989
From:	Taylor J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To:	Alicia Dixon SENATE
Shared Package
ML19324C054	List: ML19327B781 ML19327B782
References
FRN-47FR23836, RULE-PR-50 CCS, NUDOCS 8911130280
Download: ML19327B781 (3)

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UNITED sT ATEs NUCt. EAR REGULATORY COMMi$SION I

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November 1,1989 l

l The Honorable Alan J. Dixon United States Senator 230 South Dearborn Street

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Chicago, Illinois 60604 i

Dear Senator Dixon:

I am responding to a letter which you forwarded to us on September 25, 1989.

The letter conveyed the continuing concerns of Mr. H. L. Nickerson about overtime worked by personnel operating nuclear power plants.

The current NRC policy statement entitled " Policy on Factors Causing Fatique of Operating Personnel at Nuclear Reactors" is enclosed for your informatIon i

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

l 1982.. Prior to issuance, a draft of the policy was published for public connent and the input the agency received was taken into account in l

formulating the version now in effect. Since issuance, the NRC, in its a

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

e In the coucse of its nonnal reytow of policies and technical positions l

against new information and results of relevant research, the NRC is j

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continuing to study the subject of overtime and its relationship to risk.

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

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

Sincerely, j

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W Jashes M. Taylh'G i

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l-Ac' ting Executive Director

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for Operations l

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Enclosure:

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l Full. TEXT ASCll SCAN i

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33s:4 Federal Reglater / Val. 47. N:. ic / Tuesday. Inne 1.1sta / NItloos per the Appeal teenL mormal 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> day.40 hour4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> week wbDe radioactive waste disposal facihty c lean eksemake, the plant is spereting However. in the located at Snellha South Carollaa.N

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' ase,were se de Sys./ase,d event that unforseeen problent require beels for this Memorandva of eubstantial amounts of overtisse to be Agreement are two fold:(1)De Offlos i

yen,,

ws,ru,n used, or during extended periods of of the Eaecutin fagal Director.NRC, um.

, s e shutdown for refuell's major recently determined that laformation maintenance er sneler plaat gobred by South Ca.olina State giusteer Power plant Staff Wortdng medincatione, on a temporary basia, the Inspectors can be nood by the NRC in Heure followinguidelines aball be fouowed.

enforcement setions against NRC

a. As movidual abound not be~

licensees: (2) Pursuant to the previolons aosmev: Nuclear Regulatory permitted to work more thaa 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> of b South Carolina Radioactive Comadulon.

streight (excl ehth turnover thae).

Weste Transportation and Disposal Act actiost Publiation of revloed polcy

b. Amladivid abould not be of 1880 (Act No. 438), the State

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regardi nucks.t power plant staff permitted te work more thea te bosse la

==haarad control over the shipment of working e any 34 hour3.935185e-4 days <br />0.00944 hours <br />5.621693e-5 weeks <br />1.2937e-5 months <br /> period, nor more them M radioactive waste into and within the bours in any 44.bour period not som State, and intenstfled its enforcement ounseenav: On February 1t.1es2 the

1. 2 bm la y en da rkd actions.

h"".,Abro Nuclear Reguletory Commiselon

,g 9 g

l published e policy on Factors Causing c

of et least eight houre Fatisue of Operating personnel at should be eBowed between work Rovert E. Trojanowski, Regional State periods (including shin turnowr nee).

Liatoon Officer. Telephone 404-221-Nuclear Reactors." 47 FR 7361.

Comunents received since publication

d. Except durina extended shutdown 6807. U.S. Nuclear Regulatory beve revealed questione concerning the periode, the use of overtime should be Commisalon. RD. tot Marietta St N.W.,

pulicy statement. Accordingly, the conaldered on sa ladividual beslo and Buite 3100. Atlanta. Georgia 30003.

policy statement has been revised and not for the entire star on a ehlft.

Dated et Atlanta Georgia this 17th day the revised version is reprodaed below.

Recognising that very unusual of May test.

Changes include: f tlne addition of a circumstanese may arlee requiring For tlw Nuclear Regulatory Commleolon.

. eentence which exphcitly states that the devnauon from the above guidehnen.

lese p CyResDy',

ob ve of the working hour policy le such devhuon shah be authortsed by ym g

12 ve operating personnel work an S.

the plant manager or his deputy, or l

hour day. 40.bour week: (2) %e addition higher levels of managament.'fbe' Messervadum of Agressaset Between l

stf a phreae to ladicate that the stated paramount consideration la euch the U.S. Nuclear Regulator 7. Health and r% a-la-l=

l working hour restrictione are applicable authortsstion shad be that significs.nt and the S.C. Department a l

d extended periods of obutdown for reducuom h b eHecGwnen of EnvirosmeMal Centrol.Rdated k the sfue major maltenance or major

, persting personnel would be kl6 y Uso of nied Party Data and the hl plant modiacetbne: and (3) De unlikely.

Regulation of NRCla - ?"

a of cddition of a phrees exempting la addition, procedures are Radioactive Wasta to the Baram' ell calended shutdowr. petods from the

.,;:f thatwouldallowlicensed FacGity Bedisreuud r

l tenutrements to cormtM use of overtime c.peratore et the controls to be no CMuclear Syntame. lac.

only on en ladivide n e.

PerledicaHy reueved and assigned to (CNSf) low level radioactive waste Peucy en Footers Cn s, Patigue of obr duties away from the control disped factDty boekd M 8edhas.

,Operstles ponense :e 61 ear Reactore board during their tour of duty.

South Corolina, has been in operetion pon eme upomaanou ooenact since 1g71. Both the U.S' Nuclest IJsstases of operen g p' ants and Mr. Lawrence P. Crockar. (301) 405 e357 Regulatory r%==iaalon (NRC) and b cpplicants for opereting Dcunsee sheH establish controls to prevent situations Deted at betbeeds, hseryland this asth der S.C Department of Health and where fatigue could reduce the ability of of hier, sear-Environmental Control (DHEC) beve I

operating pa et.nnel to keep the reactor Per the Nucleet Regulatory Commissies, responsibilities for the regdetion of I

in a safe conditfor The controls abould Isha A.Eweiheid.

NRC licensees who ship radioactive I

locus on ehlft staffing and b use of Acamp CWef. Lissasse Quebfisettene seench weste to the disposal facihty. NRC's

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overtime-key joh4eisted factore that Dirie/en e/#umen esessie Sefety, regulatory authority is derived from the Annuence fatigue, re nam e.wm poss ee.ea ses nel Atomic Energy Act of1964, as amended. -

De objective of the controls would be es4an sees sam m e the Energy Reorganisation Act of1974, to assure that, to the extent practicable, as unended, and the regulatior.s.

personnel are not assigned to shift implementing these Acts contained in to duties while in a fatigued 'casdition that South Caroline Department of Health CFR y1.8. South Carollaa an agreement and Snvironmental Control and the State, dortves its regulatory authority could signtAcantly reduce their mental alertnese or their decision making Nuoteer Regulatory Commiselong from the opplicable State reguletions teemoesndum of Related to which are competible with the Federal capability.The controle shall apply to the plant staff who perform safety, Use of Third Party and Reguletaan regulations cited above.

related functione (e.g., senior reactor of NRC Lloonese. Shippers of CNSI operstions are regulated under l'

Radioecew Week to the Samweg operators, reactor operatore, health both e South Caroline agreement State

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payelcists, auxiliary operators, and key poemty Ucense and en NRC Baense which maintenance personnel).

De Memorandum of Agreement authortaas the receipt and burial of Enough plant operating personnel publiebed below describes the special nuclear.neterial(SNM)in q;hould be employed to maintain coopereuve regulatory policy being quantitin srettet than authorised under cdeq.aste shirt coverage without routine implemented by the NRC and the State State jurisdiction. Both DHEC and the heavy use of overtime.%e objective le of South Carohne with regard to NRC conduct routine periodic inspection to have oportting personnel work a enforcement activities et the low level for those portions of site operations

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November 1,1989 i

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The Honorable Alan J. Dixch Ll,

' United States Senator I,

'230 South Dearborn Street t

Chicago,:lilinois -60604

Dear Senator Dixon:

I am responding to a-letter which you forwarded to us on September 25, 1989.

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

overtime worked by personnel operating nuclear power plants.

I The current NRC policy statement entitled " Policy on Factors Causing Fatigue of Operating Persor.nel 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

..'i

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

(

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

t LIn the course of its normal review of policies and technical positions v

against new information and results of. relevant research, the NRC is i'

^

continuing to study the subject of overtime and its relationship to risk.

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

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

[

Sincerely,

t Original Signed By:

James M. Taylor James M. Taylor Acting Executive Director for Operations

Enclosure:

As stated on ad s es po issue rprevio M esoD ai b pthe n,

nse actual o

tf6n, orbsfates Chan'isstorf po11rcy";"

ADT:NRR*

FMiraglia 10/26/89 l*See Previous concurrences

' Document Name: GREEN TICKET 4809 0

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