ML19339B892

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Responds to NRC 800731 Interim Shift Staffing Criteria. Submits Administrative Procedures Re Overtime Policy.Sixteen Consecutive Workdays Used Instead of 14 Due to Shift Rotation.Special Policy Re Technical Advisor Unnecessary
ML19339B892
Person / Time
Site: Fort Saint Vrain Xcel Energy icon.png
Issue date: 10/30/1980
From: Warembourg D
PUBLIC SERVICE CO. OF COLORADO
To: Eisenhut D
Office of Nuclear Reactor Regulation
References
P-80388, NUDOCS 8011100383
Download: ML19339B892 (2)


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PLATTEVILLE. COLORADO 80651 October 30, 1980ii Fort St. Vrain O

Unit No. 1 Ej P-80388 Ji..

Mr. Darrell G. Eisenhut, Director P:

Division of Licensing ig,i >

U.S.N.R.C.

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-j Washington, D.C.

20555

Reference:

N.R.C. Lettir Dated a

July 31, 100 (G-M133)

Subject:

Interim Criteria for Shift Staffing

Dear Mr. Eisenhut:

It is Fort St. Vrain Nuclear Generating Station's intention to be in compliance with the staffing criteria outlined in the above referenced letter by July 1, 1982.

Administrative Procedures in the form of an Operating Order have been issued stipulating our policy concerning overtime worked for licensed operators as follows:

"This administrative procedure sets forth a policy concerning overtime work for the senior reactor operators and reactor operators. This procedure stipulates that overtime shall not be routinely scheduled.

In the event that overtime must be used, due to anticipated or unantici-pated circumstances, the following overtime restrictions shall be followed:

1) An individual shall not be scheduled to work more than 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> (not including shift turnover time).
2) An individual shall not be scheduled to work more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in any 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> period.
3) An individual shall not work more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in any 7 day period.
4) An individual shall not work more than 16 consecutive days without having two consecutive days off.

However, recognizing that circumstances may arise requiring deviation from the above restrictions, such deviacion may be authorized by the Superinten-dent of Operations or higher levels of Operations management. Appropriate documentatinu of the cause for deviation from the above shall be logged in the Station Log."

You should note that we have deviated slightly oa Item (4) from the guidance of your July 31, 1980 letter in that we have utilized sixteen (16) consecutive days so m n,

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me, Mr. Darrel G. Eisenhut Page 2 in lieu of the fourteen (14) consecutive days specified. This deviation is necessary to accommodate our shift rotation which is on a 7 day work--2 day off--7 day work--2 day off--6 day work--4 day off cycle. Without an allowance of sixteen (16) days, our complete rotational cycle would be upset in the event we should have to hold a person for work during one of the 2-day-off periods.

Any other rotational cycle will require additional personnel and possible union negotiations. Most certainly, the sixteen (16) days coupled with items (1),

(2), and (3) meets the intent of your~ letter.

Your letter also referenced the shift technical advisor position for applica-4 bility under the overtime provisions. 'Our technical advisors work a normal 40 hour4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> week and are placed on-call for back shift coverage. We do not consider j

on-call time as time worked under the provisions of Items (1),. (2), -(3), or (4). above and in this respect we do not visualize any need for adopting special adminiscrative procedures for the technical advisors.

Very truly yours,

/ ~ Wwd Don Warembourg e

Manager, Nuclear Production l

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