ML20039E752
| ML20039E752 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 12/31/1981 |
| From: | Clayton F ALABAMA POWER CO. |
| To: | Varga S Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8201110307 | |
| Download: ML20039E752 (3) | |
Text
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e Malling Address Attnraa Power Comp 1ny 600 North 18th Stree-Post Office Box 2641 Birmingham. Alabema 35291 Telephone 205 783-6081 F. L. Clayton, Jr.
Z:g' cCe$;dl't Alabama Power December 31, 1981
< O'%'j A Docket Nos. 50-348 s
50-364
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Director of Nuclear Reactor Regulation
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Washington, D. C. 20555 q;,
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a k,(T r[Tv6 N' Attention: Mr. S. A. Varga AF00 to NRC Letter Dated Aug. 7,1980 AFC0 to NRC Letter Dated Aug. 14, 1980 APC0 to NRC Letter Dated Jan. 14, 1981 APC0 to NRC Letter Dated Feb. 5,1981 APC0 to NRC Letter Dated Feb. 23, 1981 Re: JOSEPH M. FARLEY NUCLEAR PLANT - UNITS 1 AND 2 OVERTIME FOR PLANT STAFF PERSONNEL WHO PERFORM SAFETY RELATED FUNCTIONS Gentlemen:
As a part of'the Unit 2 licensing process, Alabama Power Company revised its overtime policy to comply with specific NRC requirements relating to this subject.
During the discussions with the staff concerning this matter, it was agreed that if specific problems arose from the imple-mentation of these guidelines then Alabama Power Company should propose changes to the program after implementation for a reasonable period of time. Based on the results of implementing the revised overtime policy for approximately one year, several problems frequently occur. These problems are a cause of concern by the people involved as well u by management.
The crux of the problems involve the working of split shifts due to the requirement for not working personnel more than 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> straight and the requirement to provide personnel with a break between work periods of at least 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. Split-shift situations result from shortages of personnel due to unexpected work activities or unscheduled absences.
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In these situations it is necessary to hold over a person from on-y shift to fill the first half of the otherwise vacant position in the on-coming shift, and to have the person scheduled for the following shift
/p to report early to fill the second half of the othemise vacant shift position.
Split shifts are particularly disruptive to personal living routines and patterns. They are also detrimental to on-the-job attitudes and working 8201110307 011231 PCR ADOCK 05000348 P
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..s Director of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Attention: Mr. S. A. Varga-December 31, 1981 Page 2 relationships. They are particularly disruptive when turnovers are re-quired in the mid-evening and very early morning. Split shifts are viewed by present and potential shift personnel as one of the most disliked and unacceptable characteristics of career patterns involving shift work.
Alabama Power Company, in ordar to preclude problems discussed above, proposes to revise its overtime policy as indicated below:
1.
Overtime should be limited to the extent practical for personnel performing safety-related activities.
2.
In the event that overtime must be used (excluding extended periods of shutdown for refueling, major maintenance or major plant modifications) the following overtime restrictions shall be followed unless exceptions are approved and documented:
2.1 An individual will not be permitted to work more than 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> straight (Not including shift turnover time).
2.2 An individual will not 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-hour period.
(Not including shift turnover time.)
2.3 An individual will 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.
2.4 An individual will not work more than 14 consecutive days without having 2 consecutive days off.
3.
If a plant operator, shift foreman, or shift supervisor has been working for more than 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> during periods of extended shutdown (e.g., at duties away from his normal control room functions), such individuals shall not be assigned shift duty in the control room without at least an 8-hour break preceeding such an assignment except as approved.
4.
A plant operator will not be required to work in excess of 8 continuous hours in the position of Operator-At-The-Controls.
.The Company will incorporate into plant administrative procedures this policy concerning the utilization of overtime. This procedure, which will establish work schedules and guidelines that control the use of overtime for the plant staff who perform safety related functions, will be approved by corporate management.
t For personnel required by Farley Nuclear Plant Technical Specifications, Sections 6.2.2(a) and (c), the plant manager or in his absence, the plant
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Director of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Attention: Mr. S. A. Varga.
December 31, 1981 Page 3 emergency director will approve any deviations from the overtime guidelines described in the plant administrative procedures.
For;all other personnel performing safety related functions, the group supervisor or superintendent will approve any posted-work schedule deviating from the overtime guidelines described in plant administrative procedures.
In those unexpected situations where the necessity exists, due to unfore-seen shift-to-shift contengencies or emergencies to work personnel more than 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> straight, or to not provide such personnel with a break between i
work periods of at least 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> in order to perform safety related work, t
the respective group foreman may authorize such deviation. Action on the foreman's part in these situations will be reviewed by the respective group supervisor or superintendent as a part of the normal biweekly approval process for payroll time records.
-It is the opinion of Alabama Power Company that this revised policy complies with the philosophy of limiting overtime and ensuring that adequate rest is provided to personnel while proviM., sufficient flexibility to meet actual personnel conditions and affecting only the minimum number of persons adversely.
By this letter, Alabama Pcwer Company respectfully requests NRC approval to implement the revised overtime guidelines.
If you have any questions concerning this request, please advise.
Yours very truly
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6 4 F. L. Clayton, Jr.
FLCjr:0DK:wm cc: Mr. R. A. Thomas Mr. G. F. Trowbridge Mr. J. P. O'Reilly Mr. E. A. Reeves Mr. W. H. Bradford
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