ML19339A679
| ML19339A679 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 10/15/1980 |
| From: | Morisi A BOSTON EDISON CO. |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| References | |
| 80-269, IEC-80-02, IEC-80-2, NUDOCS 8011040516 | |
| Download: ML19339A679 (2) | |
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9 BOSTON EDISON COMPANY asmana6 orricas eco morteron arassv SosTON MASSACMUSsTTS Q2199 A. V. MO NIGI NUCLEAR OPERATI B SUPPORT DEPARTMENT October 15, 1980 BECo. Ltr. #80-269 Mr. Darrel G. Eisenhut, Director Division of Licensing U.S. Nuclear Regulatory Commission Washington, D. C.
20555 License No. DPR-35 Docket No. 50-293 Response to Interim Criteria For Shift Staffina Ref. a) Letter:
D. Eisenhut to All Licensees of Operating Plants, dated July 31, 1980.
b) IE Circular 80-02 " Nuclear Power Plant Staff Work Hours" dated February 2,1980.
Dear Sir:
Boston Edison Company has examined its current staffing practices and capabilities for Pilgrim Nuclear Power Station in light of the interim shift staffing criteria provided in the above referenced letter.
This examination focused upon the primary contributors tc achieving staffing capabilities i.e. the number of candidates presently enrolled in our initial R0 license program, number of licensed R0's scheduled for S20 licensing qualification and the projected availability of can-didates for both R0 and SR0 programs within the specified time frame. Our evaluation indicates that the shift staffing at Pilgrim Station could be in compliance with the stated interim criteria by December 31, 1981, but no later than July 1, 1982.
It is therefore toward achieving the December 31, 1981 objective that we have based our schedule planning. Administrative procedures governing shif t staffing and movement of key personnel within the station shall be in place in conjunction with implementation of the shift staffing objective.
We have also reviewed your recomendations for establishing a policy within the administrative procedures which governs overtime work for SR0's, R0's and STA's.
Boston Edison Company is in complete agreement with the need for dictating sound policies which delineate overtime limitations for those personnel responsible for perfonning safety related functions and we have initiated actions to accomplish this objective.
However, Boston Edison does not routinely schedule overtime to compensate for a'1 ir. adequate number of personnel to meet the shift crew staffing requirements. Most overtime is scheduled for non-routine, non-safety related h
functions beyond the shif t crew staffing requirements. Therefore a blanket over-I time restriction which prohibits an indi"idual from workina more than 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> straight places an excessive burden on the operations organization. We shall so no405Nr
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- mosrow Eoison coupany Mr. Darrel G. Eisenhut, Director October 15, 1980 Page 2 follow the greater than 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> straight restriction in that a member of the equired shift staff shall not work more than 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> straight while perfonning safety related control room duties. Additionally, many of the applicable licensed personnel are members of a union and as such are represented by a contractual bargaining agent. Therefore, negotiation must be entered between Boston Edison and the union to develop mutual compatible criteria. These discussions have begun and upon successful resolution of this issue, we shall implement the recommended overtime policy.
If you should have any further coments or questions concerning this response, please do not hesitate to contact us.
Very truly yours,
/ pn:
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