ML20024H480

Comments on Util Practice of Allowing Personnel Performing Safety Related Functions on Operating Unit to Work Overtime. NRC Concerned W/Cumulative Effects of Overtime on Personnel. Documented Evaluation Re Guidelines to Overtime Encl

ML20024H480
Person / Time
Site:	Farley
Issue date:	05/24/1991
From:	Varga S Office of Nuclear Reactor Regulation
To:	Hairston W ALABAMA POWER CO.
Shared Package
ML20024H481	List: ML20024H480 ML20024H485
References
TAC-79150, TAC-79151, NUDOCS 9106040140
Download: ML20024H480 (8)

Text

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UNITED STATES e

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NUCLEAR REGULATORY COMMISSION

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WASHINGTON. D C. 20555

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p May 24, 1991 l

Docket Nos.

50-348 and 50-364 i

Mr. W. G. Hairston, III Senior Vice President Alabama Power Company 40 Inverness Center Parkway Post Office Box 1295 Birmingham, Alabama 35201

SUBJECT:

OPERATOR WORK SCHEDULES AT THE JOSEPH M. FARLEY NUCLEAR PLANT, UNITS 1 AND 2 (TAC N05. 79150 AND 79151)

The amount of overtime worked by operating personnel at the Joseph M. Farley Nuclear Plant (Farley), Units 1 and 2, during extended periods of shutdown has been a concern to the Nuclear Regulatory Commission (NRC) staff. Alabama Power Company's (APC0's) practice on overtime has been that during a single-unit outage, the unit staffs of both the operating unit and shutdown unit are placed on the same overtime schedule.

This schedule typically includes shif t rotation that results in operators working up to 84 hours9.722222e-4 days <br />0.0233 hours <br />1.388889e-4 weeks <br />3.1962e-5 months <br /> in a 7-day period.

The NRC staff recognizes that extended outages such as refueling often necessitate higher levels of overtime usage than other phases of operation.

As discussed in the enclosed evaluation, Technical Specifications 6.2.2.f for Farley, Units 1 and 2, as well as NRC guidance, allow higher levels of overtime during extended periods of shutdown for refueling, major maintenance or major plant modifications.

However, these levels were intended to apply to a shutdown unit only.

The staff's position is that APC0's practice of allowing personnel performing safety-related functions on the operating unit to work the same overtime schedule as the unit staff in an extended shutdown meets neither.the intent of either the Farley, Unit 1 or Unit 2, Technical Specifications, nor NRC guidance on this issue.

Technical Specifications 6.2.2.f for both Farley, Unit I and Unit 2, state that the objective shall be to have operating personnel work a nominal 40-hour week while the plant is operating. Therefore, we require that you modify your work schedules-so that during single-unit outages, the unit staff of the operating unit continues to work a nominal 40-hour week per Technical Specification 6.2.2.f.

As APC0 has utilized its current practice for scheduling overtime,for a significant period of time, and the staff has indicated in the post that the practice appeared to be acceptable (see Inspection Report Nos. 50-348/88-05 and 50-364/88-05), the imposition of this change was evaluated as a potential backfit in accordance with the criteria contained in 10 CFR 50.109.

Imposition of this change has been found to be justified in accordance with th f

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• criteria contained in 10 CFR 50.109(a)(4) to bring operation of Farley, Units 1 and 2, into compliance w:th their licenses. Therefore, a backfit anelysis per the standards of 10 CFR 50.109(a)(3) is not required.

The documented evaluation prepared purstant to 10 CFR 50.109(a)(6) is enclosed.

Within 30 days, you are required to ietrond to this letter indicating your plen for resolving this issue )nd your schedule for compliance.

If you disagree with the staff's badfit determinatien, you have the right to appeal the determination. Your r!quast for appeal shcu id be addressed to the Directar, Office of tiuclear Reactor Regulation, and should copy the Executive Director for Operations.

The appeal should take into account the staff's evaluation, previous correspondence, and any other information that is relevant to the backfit dete:tination.

In addition, we acknowledge that your practice of scheduling overtine for the shutdown unit staff in excess of the guidelines contained in Technical Specifi.

cation 6.2.2.f, and NRC guidance en cvertin,e is allowed with proper approval.

However, we do not believe that you are t.eetir g the intent of the Technical Specificaticns and NRC guidance by routinely preplanning the amount of overtin,e currently worked. The hTC is concerned with the cumulative effects of cvertime on personnel performing safety-related activities, especially when two outages occur in proximity such as the recent Unit 2 outage ending on January 6,1991, and the Unit 1 outage beginning on March 8, 1951. Fe strongly recomend that you reconsider your overtime scheduling practices for the unit staff in an extended shutdown.

S i ncere l),

Orignal signed, j:

Steven A. Varga, Director Division of Reactor projects - 1/1I Office of Nuclear Reactor Regulation

Enclosure:

As stated cc:

See next page

• See previcus concurrence

• • See previous ccncurrence sheet. Acceptable to OGC-Enforcement.

0GC Rulemaking does not believe this is a t+ckfit.

Does not concur.

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r-DISTRIBUTION Docket File NRC PDR Local PDR

5. Varga 14-E-4 G. Lainas 14-H-3 L. Reyes R11 D. Verre111 R11 A, Mendiola 14-D-20 P. Anderson 14-D-20 t

S. Hoffman it-B-20 J. Taylor (EDO)

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4 J. Roe 10H5 W. Russell 12G18 F. Miraglia-12G18 P. Cota-12-E-4 J. Wermiel 10-D-24 G. Maxwell (SRI)

OGC 15-B-18 E. Jordan HNBB-3302 ACRS(10)

P-315 Farley Plant File l

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Mr. W. G. Hairston, !!!

Alabama Power Company Joseph M. Farley Nuclear Plant CC:

Mr. R..P. Mcdonald Resident inspector Executive Vice President U.S. Nuclear Regt>1atory Conrnission 4

Nuclear Operations P. O. Box 24 - Route 2 Alabama Power Company Columbia, Alabama 36319 P. O. Box 1295

- Birmingham Alabama 35201 Regional Administrator, Region !!

U.S. Nuclear Regulatory Commission Mr. B. L. Moore

10. Marietta Street, Suite 2900 Manager, Licensing Atlanta, Georgia 30323 Alabama Power Company P. O. Box 1295 Chairman Birmingham, Alabama 35201 Houston County Commission Dothan, Alabama 36301 Mr. Louis B. Long, General Manager Southern Company Services, Inc.

Claude Earl Fox, M.D.

- P. J. Box 2625 State Health Officer Birmingham, Alabama 35202 State Department of Public Health State Office Building Montgomery, Alabama 36130 Mr. D. N. Morey General Manager. Farley Nuclear Plant James H. Miller, 111. Esq.

P. O. Box 470 Balch and Bingham Ashford, Alabama 36312 P. O. Box 306 1710 Sixth Avenue North Mr. J. D. Woodward Birmingham, Alabama 35201 Vice-President - Nuclear l

Farley Project Alabama Power Company P. O. Box 1295 Birmingham, Alabama 35201

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