ML20049J859
| ML20049J859 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 03/24/1982 |
| From: | Daltroff S PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8203290164 | |
| Download: ML20049J859 (3) | |
Text
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6 PHILADELPHIA ELECTRIC COM PANY 2'301 M ARKET STREET P.O. BOX 8699 ff
b PHILADELPHIA. PA.19101
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V-d o.1g%~(psJJaa SHIELDS L. DALTROFF
. = = = _.
s S
e March 24, 1982 Re :
Docket Nos. 50-277 50-278 Mr. Darrell G.
Eisenhut, Director Division of Licensing U. S.
Nuclear Regulatory Commission Washington, DC 20555 REFE RENCE S:
1)
S.
L.
Daltroff (Philadelphia Electric Co.) letter to D.
G.
Eisenhut (NRC),
dated December 22, 1980 2)
S.
L.
Daltroff (PECo) letter to D. G.
Eisenhut ( N RC ), dated March 10, 1981.
3)
S.
L.
Daltroff (PECo) letter to D.
G.
Eisenhut (NRC), dated March 31, 1981
Dear Mr. Eirenhut:
This letter provides notification of our plans to revise Philadelphia Electric Company's overtime policy for shift operating personnel and health physics and chemistry technicians at the Peach Bottom Atomic Power Station to bring it into agreement with the NRC's revised guidance published in the Federal Register, page 7352, on February 18, 1982.
4 The original overtime policy for shif t operating personnel and health physics and chemistry technicians at Peach Bottom was developed in response to the guidance presented in NUREG 0737, Item I.A.1.3.1, Shift Manning, and was described in references 1, 2, and 3.
Subsequently, the NRC staff proposed to the Commissioners new guidelines intended to resolve the 8203290164 820324 DI PDR ADOCK 050C0277 P
PDR gg
O Mr. Darrel G.
Eisenhut, Director Page 2 inconsistencies in the previous guidance.
After consideration of the NRC staf f's proposal, the Nuclear Pegulatory Commission issued a new overtime policy, described in the Federal Register previously referenced.
The new overtime policy requires licensees to establish controls to prevent situations where fatigue could reduce the ability of operating personnel to keep the reactor in a safe condition.
Further, the licensee is required to employ enoagh plant operating personnel to maintain adequate shift coverage without routine heavy use of overtime.
However, in the event that unforeseen problems require substantial amounts of overtime to be used, the rule specifies the following restrictions:
a.
An individua3 should 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 (excluding shift turnover time).
b.
An individual should 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 /> in any 24-hour period, nor 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 more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in any seven day period (all excluding shift turnover time ).
c.
A break of at least eight hours should be allowed between work periods (including shift turnover time).
d.
The use of overtime should be considered on an
(
individual basis and not for the entire staff on a shift.
Deviations to the above restrictions are permitted upon authorization by the plant manager or his deputy.
In addition, the new policy encourages procedures to permit licensed operators at the controls to be periodically relieved and assigned to other duties away from the control board during their tour of duty.
It is our understanding that the new policy permits more flexibility in the application of overtime rules without increasing the total number of hours worked over a two day and one week period.
Therefore, the intent of the original policy to prevent plant personnel from performing safety-related functions while in a fatigue condition is retained.
However, the new policy simplifies the overtime rules which will have the effect of reducing bookkeeping requirements, and improving administration of an effective overtime policy.
Further, the greater flexibility in the new rules will in some situations reduce fatigue on shift personnel by permitting a more orderly coverage of a shift vacancy.
o Mr. Darrel G.
Eisenhut, Director Page 3 We plan to implement the new overtime rules for shift operating personnel and health physics and chemistry technicians in accordance with the NRC's revised policy published in the Federal Register as soon as the applicable Peach Bottom administrative procedure is revised.
The shift operating personnel subject to the new policy are the Senior Reactor Operators, Peactor Operators, Shif t Technical Advisors, and non-licensed operators.
Should you have any questions regarding this matter, please do not hesitate to contact us.
Very truly yours, 3
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