ML19350C656
| ML19350C656 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 03/31/1981 |
| From: | Daltroff S PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-1.A.1.3, TASK-TM NUDOCS 8104060546 | |
| Download: ML19350C656 (3) | |
Text
4 PHILADELPHIA ELECTRIC COMPANY 2301 M A RK ET STR EET M
P O. BOX 8699 1881 1981 PHILADELPHI A. PA.19101
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Eisenhut, Director Division of Licensing US ?!uclear Pe;ulatory Comission hshington, PC 2055c Dear Ur.
Fisenhut:
Section I.A.1.3 of !;U3EG 0737
" Cl a r i fi c a t i o n o f ** Action Plan P e qu i r am a r.t s," ax*aeds tha shift - v e ns ovartima criteria to all plant starf no perform refety-related fu.cti:rc.
B correscondence dated Februar'/ 20, 19R1 c.
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Paltr:f f to P.
O.
Eisanhut, we ccamitted to submittini a crocosed plcn for extending the evertime rules to other personnal by varch 31, 1941.
This letter prasents our croposal on this matter.
?!UREG 07 37, section I.A.1.?, requires administrative procedur es setting forth a policy ragarding workin; schedules such that the use of overtine is avoided to the extent practical for the plant staf f who perform safety related functions.
This is further defined to include senior reactor operators, reactor operators, health physicist, auxiliary operators, I& C' l
technicians, and key maintenance personnel.
The following overtine restrictions cre specified:
Rule 1.
An individual should not be permitted to work more than 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> straight.
l Rule 2.
There should be a break of at least 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> between all werk periods.
Rule 3. An individual should 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.
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Rule 4 An individual should not be required to werk mora than 14 consecutive days without havin?,
2 consecutive days off.
Deviations to the above restrictions are parmitted upon clant mars,er authorization.
Tha troC criteri i furthe-statas thst these rules do not apply during extended periods of shutiown for rafueling, major maintenance or major plant modifications.
These overtime restrictions have been applied to the Senior Reacter Nara* ors, ca?ctor "parators, and the Thirt ?achnical Adv". sors at Panch Pottem as described in corraspondanca dated December 22, 1990, S. L. Daltrof f to E.
G.
Eisenhut, and it is plannad to apply them to non-licensed operators by April 30, 1981.
For other personnel ( e.g., health physicists, !! C tachnician and maintenance personnel), wa propose the 'ollowing overtime policy to be implemented by April 30, 19c1 for parsonnel involved in performing a safety related funct.on on the operating unit.
1.
An individus1 shall not be scheduled in advance to work more
'than 1? consecutive hours (excluding meni period s), nor more than'14 consecutive days.
2.
If circumstances arise which require an individua! to wo r k more than 12 consecutive hours, such werk shall be. authorized by the individ ual's supervisor, in accordance with approved procedures, and with appropriate doc:nentation of the cause.
The MRC overtime restrictions, rules 2 and 3, were considered to be of minimal value for other groups because the application of rules' 2 and 3-could result in.a need to change personnel in the middle of specific work assignments resulting in job disruptions, a reduction in the task specific experience level, and poor transfer of task information due to turnover dif ficul ties ( e.g., lack of man-to-man interf ace between a worker engaged on a task rbrough late in the day and his replacement).
This disruption in canpower scheduling coula reduce the quality of job performance and may impact on plant safety.
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Page 3 As previously stated, we are proposing a modified overtime rule for other plant personnel performing safety related functions.
Application of rules 2 and 3 appears to be of little value due to the nature of the job functions of non-operating personnel, because of increased administrative controls, and reduced task specific experience level.
Very truly yours,
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