ML20062B488
| ML20062B488 | |
| Person / Time | |
|---|---|
| Issue date: | 07/21/1982 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| References | |
| REF-10CFR9.7 NUDOCS 8208040539 | |
| Download: ML20062B488 (58) | |
Text
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Talachc=e: (202) 554-2345 8208040539 820721 PDR 10CFR PT9.7 PDR
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1 UNITED STATES OF AMERICA 2
NUCLEAR REGULATORY COMMISSION 4
BRIEFING ON MINIMUM NUMBER OF SHIFTS 5
REQUIRED AT OPERATING REACTORS 6
7 8
PUBLIC MEETING 9
10 Nuclear Regulatory Commission Room 1130 11 1717 H Street, N.W.
Washington, D. C.
12 Wednesday, July 21, 1982 13 14 The Commission met, pr.suant to notice, at 15 2:04 p.m.
16 BEFORE:
17 NUNZIO PALLADINO, Chairman of the Commission 18 VICTOR "ILINSKY, Commissioner JOHN AHEARNE, Commissioner 19 THOMAS ROBERTS, Commissioner 20 STAFF AND PRESENTERS SEATED AT COMMISSION TABLE:
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21 S. CHILK 22 F. BEMICK R. LEVI 23 H. DENTON J. ZWOLINSKI
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24 J. KRAMER 25
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DISCLAIMER This is an ' unofficial' transcript of a meeting of the United States
~.. Nuclear Regulatory Conmission held on Juiv'21. 1982 in the iCocmission's offices at 1717 H 5treet, N. W., Washington, D. C.
The meeting was open to public attendance and observation.
This transcript has not been reviewed, corrected, or edited, and it may contain inaccuracies.
The transcript is intended solely for general infomational purposes.
As provided by 10 CFR 9.103, it is not part of the forinal or informal record of decision of the matters discussed.
Expressions of opinion in hthis. transcript do not necessarily reflect final detenninations or beliefs.- Ho pleading or other paper may be filed with the Commission in
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any proceeding as the result of or addressed to any'orize.
statement or argument contained herein, except.as the Comission may auth a$
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CHAIREAN PAiLADINO:
With regard to the topic 3
scheduled for this af ternoon, the Commission meets to
~s 4
receive a briefing from the staff on the minimum number 5
of shifts requiral at opera ting reactors.
6 Currently the Commission has no specific 7
regulations that require a minimum number of shifts at 8
operating reactors.
However, the Nuclear Regulatory 9
Commission has issued regulatory guidance that has an 10 indirect impact on the number of shifts required, such 11 as guidance on training programs and the use of 12 overtime.
The staff will provide recommendations on the 13 question of the minimum number of shifts.
(")
14 For this meeting the Commissioners have agreed 15 to try a different approach than that normally used.
We 16 will attempt to listen to the staff's briefing without 17 interruption, except for questions of fact.
l 18 (Laughter.)
19 CHAIRMAN PALLADINO:
After the staff has 20 concluded the formal presentation, of course the meeting 21 will be open to questions from the Commissioners.
22 Now unless any of my fellow Commissioners have 23 additional remarks ---
.-(,)
24 (Laughter.)
25 COMBI 55IONER AHEARNE:
Wasn't there another ALDERSON REPORTING COMPANY,INC, i
I 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (2C2) 554-2345
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1 factor in that the staff agreed to limit its V) 2 presentation.
3 CHAIRMAN PALLADINO:
Oh, yes, to 30 minutes.
4 COMMISSIONER GILINSKYs Thirty minutes!
5 (Laughter.)
6 CHAIRMAN PALLADINO:
I think they are going to 7
be more brief.
8 We also had as a condition of this that we 9
start on time and we end on time.
10 COMMISSIONER AHEARNE:
And the staff would 11 restrict its presentation to a fixed period of time.
12 CHAIRMAN PALLhDINO:
Thirty minutes at most.
13 You are free to be briefer.
O Cl 14
( Laugh te r. )
15 MR. DENTON:
I don't think we will exceed the 16 30 minutes, Mr. Chairman.
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17 There have been some significant changes in 18 the handouts that we had previously given you.
John 19 Zwolinski on my right will make the presentation, and to i
20 my left is Joel Kramer, the Assistant Division Director.
I 21 We have established that there will be no 22 utility with less than five shifts in operation by the l
23 end of 19.82.
So based on our most recent finding of
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24 that, we will not be recommending any change in our l
25 present practice considering that those number of shifts t
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1 in combination with our requirements on overtime and 2
training 3
COMMISSIONER GILINSKYs There is no 4
requirement on the number of shifts now, is there?
5 MR. DENTON:
That is correct.
6 COMMISSIONER GILINSKYa Is that a factual 7
question?
8 (Laughter.)
9 MR. DENTON:
I am getting into John's 10 presentation and I had best turn it over to him.
11 CHAIRMAN PALLADINO:
Well, why don't we give 12 him a chance to say it.
13 COMMISSIONER AHEARNEa Go ahead, John.
14 NR. ZWOLINSKI Correct, there is.no 15 regulation.
16 COMMISSIONER GILINSKY Thank you.
~ 17 (Slida presentation.)
18 MR. ZWOLINSKI M r. Chairman and l
l 19 Commissionars, as you know the staff has not developed a 20 paper on the subject of the number of shifts.
21 Therefore, in this area where most enjoi an opinion, I 22 have attempted to develop the facts ragarding the number 23 of shifts.
Based on my remarks and additional
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24 discussion today, I trust the staff vill be provided 25 firm guidance regarding this issue.
a ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345
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1 As a means to introduce the subject, the 2
Commission has not in the past attempted to specify a 3
minimum number of operating shifts to be used at k.
4 commercial nuclear power plants.
Rather, the emphasis 5
has been placed upon the number of operators per shif t 6
in various operating modes, the requirements for 7
operator requalification training and more recently on 8
the need to control usage of overtime.
9 In practice these staff requirements have 10 effectively established the number of shifts that must 11 be utilized by a utility to operate the nuclear power 12 plant.
13 Four operating shifts are required in, order to k-14 allow 24-hour coverage by eight-hour shifts and provide 15 for days off, leave and illness.
The need for operator 16 retraining requires additional licensed operators, in 17 addition to the four shift complement.
18 COHHISSIONER GILINSKY I have been in several 19 plants where people were working 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> a day, or at 20 least more than one plant.
21 MR. ZWOLINSKI That is possible.
l 22 COHHISSIONER AHEARNE:
A factual question.
23 Does not 737 and its associated statements say 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> (j) 24 is the upper limit?
25 MB. ZWOLINSKIa That is correct.
Our overtime i
ALDERSoN REPORTING CoMPAl'Y,INC, 400 VIRGINIA AVE., S.W WASHINGTON D.C. 20024 (202) 554 2345
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1 statement talks of eight hours and then a maximum amount 2
of overtime of up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> with 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for the work 3
week.
4 By the time of the THI-2 accident most 5
utilities were employing a five-shif t rotation in order 6
to provide for ad' equate retraining time.
The continuing 7
emphasis on working hour limitations and the more 8
stringent retraining requirements since TMI-2 have led 9
those utilities with newly licensed plants to adopt a 10 six-shift rotation scheme so that one f ull shif t can be 11 devoted to retraining without the necessity of working 12 overtime.
Other licensees are adopting a six-shift or 13 even seven-shift rotation in order to meet the various 14 sta ff requirements.
15 We have recently completed an industry 16 survey ---
17 COMMISSIONEB GILINSKY:
I have got to raise a 18 point here.
When we approved Salem, aLi I must say I 19 wasn't as svare of this problem at that ti3e as I think 20 I am now, they were on three shifts, as I recall.
Is
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21 that not right?
22 HR. DENTON:
I don't recall the facts of 23 Salem.
Our Standard Review Plan uses as a guide five I,'-
24 shifts and we have exercised flexibility.
25 What we are going to tell you today are the ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 234$
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1 results of a survey of all operating plants and where 2
they stand.
There have been some exceptions for short 3
periods of time, such as strikes or storms or new 4
licensees who were not up to those standards, but we can 5
report today on what the experience is.
6 COMMISSIONER GILINSKYa The reason I raise 7
this is because I think the picture that is getting 8
painted here is a rather more cheerful one than at least 9
the facts up to now warrant.
It may well be that it is 10 getting corrected.
11 CHAIRMAN PALLADINO:
Why don't we go through 12 the results of the survey and I thin,k that will answer 13 your question.
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14 HR. ZWOLINSKIs We have recently completed an 15 industry survey which indicates that all licensees will 16 ha.ve by the end of this. calendar year five-shift 17 rotation schemes in place.
18 As Mr. Denton noted, our SRP Section 13.1.2 19 review procedures does indeed identify that the staff is 20 looking for five-shift rotation to be implemented.
On 21 the NTOL's we have gone so far as to push for the six 22 shifts.
23 In past practice, and I think this will answer
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24 one of your questions, Commissioner Gilinsky, we have 25 found a two-shift operation for start-up situations
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ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345
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1 where there has been the need for a large number of 2
licensed personnel to perform that function.
3 A three-shift operation is very typical for 4
refueling opera tions.
We find as we go into the four,
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5 five and six-shift rotational schemes retraining and 6
overtime are affected.
The most shifts, the better the 7
retraining, the less overtime.
8 OHAIRMAN PALLADINO:
What do you mean by 9
"brief periods" in the first one?
10 MR. ZWOLINSKI:
I am talking two to three to 11 four weeks.
12 COMMISSIONER GILINSKY:
Let's see, where does 13 that happen?
I didn't realize it was for that long.
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14 Ihis is for regular operation of a plant at full power?
l 15 ER. ZWOLINSKI Your example of Salem, they i
16 for a short period of time were on two shifts of 12 17 hours1.967593e-4 days <br />0.00472 hours <br />2.810847e-5 weeks <br />6.4685e-6 months <br /> each.
18 COMMISSIONER GILINSKYa They were on a strike?
19 ER. ZWOLINSKI:
There was this strike, that 20 was one situation.
But when you go back to when ther 21 were initially licensed they were on a three-shift l
22 rotation.
23 To the Sales question, there was not
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24 suf ficient licensed personnel at that time when ther i
25 were initially licensed.
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1 COMMISSIONER GILINSKY Harold earlier was x..-
2 saying that there are certain circumstances where we 3
have had a smaller number of shifts, for example, at s
4 start-up.
Now it seems to me start-up is a time when 5
there are just a lot of thin'gs happening and it would be 6
the time when you don' t want to ---
7 HR. ZWOLINSKIs Okay.
The two-shift can be a 8
little bit of a misnomer.
If I had six-shif t rotation 9
in place, I would have three shifts working at one 10 period of time and three shifts working at the other 11 period of time.
I need a large number of qualified 12 people at any given 12-hour incremen t.
13 COMMISSIONER APEARNE:
I would point our, Vic, 14 that some time ago we originally had a rule or a 15 proposed rule that would have restricted the amount of 18 time, and the Commission for a variety of reasons I 17 guess backed off of that and ended up with the 12 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br />.
There was a movement to try to restrict the 19 amount of time a person could work.
20 ER. DENTO'Ns There was a problem in the first 21 few OL's with the number of shifts becabse we had made 22 these increases in overtime requirements and staffing, 23 but I don't think that is a problem in the current OL
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24 vintages, such as Susquehanna or LaSalle or Southern Cal.
25 MR. ZWOLIN SKI s That is correct.
They were g
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400 VIRGINIA AVE., S.W., WASHINGTON 0.C. 20024 (202) 554 2345
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1 all pretty much five and six shifts.
2 COMMISSIONER AHEARNE But you say that during 3
the refueling for nonpower operation, is that when the 4
three-shift operation is common?
5 HR. ZWOLINSKI Most typically.
There has 6
been, as Harold mentioned, the strikes.
Recognize 7
during refueling you are going to longer hours.
It is 8
is ten days to two weeks and the three-shift rotation 9
seems to have evolved.
10 If I can move along, there have been a number 11 of things that have driven the number of shif ts, clearly 12 the three issues that we have identified on this slide.
13 In addition to that, there have been union agreements, a 14 career path, vacations, sick leave concerns, the issue 15 with respect to refueling and more recently the 16 requirement fer the second SRO indeed may be driving the 17 industry to reduce the number of shifts over a very 18 short period of time.
19 We in fact just recently queried Fort St.
20 Yrain and they were on six-shif t rotation and with the 21 implementation of the second SRO had to'back down to 22 five-shift rotation to accommodate the second SRO.
We 23 feel that say be a small burp in the system.
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24 The general effect of this that indeed most 25 utilities are committed to a five or more shift rotation.
kg ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W WASHINGTON, D.C. 20024 (202) 554-2345
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CHAIRMAN PALLADINos What do you mean "are 2
committed to"?
You mean they plan to?
3 MR. ZWOLINSKI:
The results of Our. survey have 4
shown, and in fact it is the next slide, th a t 5
essentially all the utilities are on a five-shift 6
rotation working philosophy, except that there are i
7 selected utilities that may have two or three operators 8
move along and they will have to adopt a modified 9
four-shift rotation.
10 COMMISSIONER AHEARNE:
Which plan t is that 11 that had the three-shift rotation?
12 MR. ZWOLINSKIa I wanted to preface that.
It 13 turns out that the three is no longer in existence.
We 14 thought that was Fort St. Vrain and we got on the phone 15 and straightened that.
18 CHAIRMAN PALLADINO:
Where does Fort St. Vrain 17 come in now?
18 ER. ZWOLINSKIa They are down under five 19 shifts and planning for six shifts.
20 CHAIRMAN PALLADINO:
Should I cross out that 21 first one?
22 NR. ZWOLINSKIa Yes, you cross that out and 23 the 17 becomes 18 on the slide under " Number of
()
24 Facilities," and the 24 goes to 25.
25 I thought the most impressive part of the i
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
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1 survey was the vast number of utilities that indeed are
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headed toward seven shifts.
That bottom one is 7
4 Fitzpatrick.
5 Again, for those two that are on four shifts, 6
'ooth of those are moving vigorously to indeed have five 7
shifts in place by the end of this year.
8 COMMISSIONER AHEARNE:
Which ones are those?
9 NR. ZWOLINSKIa They are North Anna and 10 EcGuire.
11 What I have developed'on the next slide are 12 the pros and cons that I felt would tend to drive either 13 the need for six shifts or five.
I think the bottom 14 line to much of this is the need to assure retraining 15 and that the operators are not working an extensive 16 amount of overtime and that their vacations and sick 17 leave are addressed.
18 I think when you have the six-shif t rota tion 19 in place it allows for much better planning of outages.
20 We find that you would have additional licensed 21 personnel available to conduct your periodic test as 22 required by the technical specifications.
23 Selected cons of the six-shift, there is a
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24 population out there of reactor operators that relies on 25 a measure of overtime as an addition to their pay check, ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
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1 and we would reduce the amount of overtime with six 2
shifts in place.
3 COMMISSIONER GILINSKYa What a minute, that is
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4 an odd disadvantage for us to put forward.
5 COMMISSIONER AHEARNE:
But it was a major G
disadvantage that was raised when we were debating 7
previously the length of maximum time you would be 8
allowed.
9 COMMISSIONER GILINSKY:
Well, I still think it 10 is an odd thing for us to be bringing up.
11 COMMISSIONER AHEARNE:
I agree.
We shouldn 't 12 have that as one of our f actors of consideration.
13 MR. ZWOLINSKI:
Well, we will scratch that one
('l 14 off.
15 COMMISSIONER GILINSKYs I mean it may very 16 vell be that from the point of view of an individual 17 operator that is a disadvantage and he would like to l
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18 work as many hours as possible, but it seems to be 19 saying that we would like operators to work as many 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> as possible.
21 MR. DENTON:
The pros and cons I think were 22 not just NRC cons, but how you perceive it would affect 23 opeations.
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24 COMMISSIONER GILINSKY:
Would you say that 25 operators would quit because they won't make as much v
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
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1 money as they expected to and therefore there won't be 2
enough operators, which I d'oubt.
3 3R. ZWOLINSKI I am not sure I can make that Ns 4
statement, Commissioner Gilinsky.
The point was one of 5
affected the man's pay check.
I will strike that from 6
ay notes.
7 COMMISSIONER AHEARNE:
It is a morale factor.
8 MR. ZWOLINSKI:
I think so'.
9 There is one con that is not on the 10 vievgraph.
If you have six-shift rotation, the operator 11 will be on shift in the control room about 50 percent of 12 his normal work year time.
13 CHAIRHAN PALLADINO:
Say that again?
(-)
.14 ER. ZWOLINSKI:
If you have the six-shift 15 rotation in place, the operator spends about half his 16 time in the control room.
The other half is ---
17 COMMISSIONER GILINSKYa Half of the working 18 time.
19 MR. ZWOLINSKIa Half of his working time.
The 20 other half would be in retraining, in his planned 21 vacations and the other shif t is a relisf shif t in which 22 he is assisting your technical support group, for 23 example.
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24 On the five shifts the pros and cons, if you l
l 25 assume that the five shif ts are fully manned and there ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
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are relief personnel ---
2 COMMISSIONER GILINSKY:
Just to go back to 3
that previaus one, you never put the fact that the 4
operators may make less money ---
5 COMMISSIONER AHEARNE:
On the six shift.
6 COMMISSIONER GILINSKY:
You said it may need 7
to attract more candidates into RO/SRO training 8
programs.
I don't see that that is a con either.
It 9
sounds to me like that may be a good thing.
10 MR. ZWOLINSKI:
If I adopted a six shift over 11 a short period of time, what would evolve is that the 12 industry would usa their trainers or their licensed 13 operators that are on the engineering staff to come in 14 and make up that shift.
You may take away from some of l
15 the other job activies that are needed to be 16 ~ accomplished, and I don 't think we want to detract f rom 17 retraining.
t 18 HR. DENTON:
I think it is hard to find a 19 safety con for having six, seven or eight shifts.
I 20 just come out that five shifts met all the 21 requirements.
I don 't want to stretch to find things 22 vrong with more than five shifts, but I would like to 23 turn the page and show that five shifts fully satisfy
()
24 COMMISSIONER GILINSKY:
In terms 6f costs and 25 benefits obviously it costs more money and that has got j.(.-
l ALDERSoN REPORTING COMPANY. INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
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1 to be taken into account.
2 MR. ZWOLINSKIt' To the five shifts, again the s
3 five-shift rotation _ allows for full shift coverage and a 7,,
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4 full retraining program.
What is requifed is a number 5
of relief personnel to fill in for whattI had called 6
intangibles on the slide.
I am talking about sick leave 7
or the vacation time.
8 COMMISSIONER AHEARNE:
Wha t do you mean by
\\
9 "use of training' personnel to backfill operations"P 10 MR. ZWOLINSKI:
If I have five shifts with no 11 relief personnel, and as the shift is beginning I find 12 that a man is not reporting to work, I typically go to 13 their training program and take a man out of training
(
14 and put hit -cn. the shif t.
It affects his retraining 15 program.
16 MR. DENTON:
The ideal case I think would be i
17 five shifts plus a few people wh'o would be able to step 18 in the event that somebody on the normal four shif ts was 19.not able to fill his normal slot.
One way to do that 20 would he to have a sixth shift.
Then you guarantee that 21 you alwa ys h' ave five shif ts plus one or' two people who 22 don ' t' normally work in this capacity.
23 COMMISSIONER AHEARNE:
Are you saying that the
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24 principal of the sixth shift is to-provide a float?
25 MR..ZWOLINSKI:
Yes, you are covered at all ALDERSON EPoRTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON D.C. 20024 (202) 554-2345
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1 times and you do not detract from your retraining 2
program.
3 COMMISSIONER AHEARNE:
But in the absence of y
4 that need to fill in an unexpected hole, doesn't the 5
five-shift cover the training program?
6 MR. DENTON:
Five shifts provides four shifts 7
for the normal work and one shif t being t ra ined.
So 8
then that meets the requirements.
9 COMMISSIONER AHEARNE:
So the extra people 10 above the five-shift are floaters to cover this 11 unexpected ---
vacancy.
That is right.
12 MR. DENTON 13 CHAIRMAN PALLADINO:
But when you have six 14 shifts, does the six shift come in the rotation process?
15 MR. ZWOLINSKI Yes, they do.
The sixth shift 16 would be assigned to performing duties such as assisting 17 your technical support group at the plant and they would 18 perform other roles in assisting the training 19 organization.
20 CHAIRHAN PALLADINO:
Always or do they get 21 into the same cycle as one of the other'five?
Is there 22 enough rotation so that this sixth group or sixth shift 23 maintains its viability?
,(,)
24 3R. ZWOLINSKI M r. Chairman, it is my 25 understanding th'a t the four licensed operators when they ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345
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1 nove of f of their licensed duties in the control room 2
that they don't work as a team of four people in support 3
of the engineering group, for example.
They have t
4 responsibilities that they carry.
5 COMMISSIONER AREARNE:
Maybe there is more to 6
it, but so f ar it sounds like the Navy has its people 7
chip paint.
8 COMMISSIONER ROBERTS:
I don't follow you.
9 COMMISSIONER AHEARNEs Well, on shipboard 10 during lengthy periods when there is not too much to do 11 you have got to keep the crew busy because if the crew
. 12 isn't busy then they have got other kinds of morale 13 problems.
So you have them chip the paint and then sand
(-)
14 it down and then repaint it and then chip the paint and 15 sand it down and repaint it.
16
(.Lau g h t e r. )
17 COMMISSIONER ROBERTS:
I have a hard time with 18 that, John.
I spent three years on a destroyer and I 19 don't agree with th a t.
20 (Laughter.)
21 COMMISSIONER AHEARNE:
This is purportedly a 22 carrier.
23 COMMISSIONER ROBERTS:
I don't know anything
()
24 about carriers.
25 (Laughter.)
/
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ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
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1 COMMISSIONER GILINSKYa I don't think these 2
a re f actual questions.
3 (Laughter.)
73
(
4 CHAIRMAN PALLADINO:
You are right.
5 COMMISSIONER AHEARNE4 I was just concerned 6
that so far it really sounded like that sixth shift 7
COMMISSIONER ROBERTS:
You are using a shift 8
meaning a team of people.
9 MR. ZWOLINSKIa Yes.
10 COMMISSIONER ROBERTS:
Tell me what a shift is 11 as a period of work in hours.
12 MR. ZWOLINSKI:
We have been using an 13 eight-hour period as the typical shif t.
14 COMMISSIONER ROBERI5:
Is that standard 15 practice?
16 MR. ZWOLINSKI Yes.
17 CHAIRMAN PALLADIN0s Do we have any 18 requirement on that?
19 COMMISSIONER AREARNE:
No.
20 MR. ZWOLINSKIs Not for the eight hours.
We 21 have an overtime requirement.
~
22 CHAIRMAN PALLADINO:
Eventually I am going to 23 ask you to review what our requirements are so that we i [)
24 can keep them in perspective.
25 COMMISSIONER GILINSKY:
I think there is
\\._l ALDERSON REPORTING COMPANY. INC.
400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
20 1
another factor which is that we are talking about how 2
such a plant budgets for, and they are not going to have 3
a full complement of operators at all times.
People
[
4 come and go and various other factors.
So that if you 5
are budgeting for six, you may end up with a full 6
complement for five.
That is one of the things that 7
gets tsken care of when you have six shifts.
Then if 8
you are budgeting f or five, you may end up with four as 9
a practical matter.
10 MR. DENTONs I was a little surprised by the 11-results, because, like you, I recall tha t they had 12 pretty skiapy staffing _ a while back and I ayi pleased to 13 see that everyone has actually moved as far as they
()
14 have.
It looks like about half of the utilities on your 15 chart are moving towards six.
16 CONNISSIONER GILINSKYa I agree.
It looks 17 like a very much better situation than I must say I 18 expected.
j 19 MR. DENTON:
I had not expected it to turn out 20 tha t ' favors ble either.
21 MR. ZWOLINSKI If I might move to the future 22 actions that the Commission might consider.
I developed 23 this particular slide assuming that we had a lot of bad 24 actors, three and four-shif t operations, and the
}
25 Commission might consider getting on with perhaps a I _,
ALDERSON REPORTING COMPANY,INC, 400 VIRGIN!A AVE., S.W WASHINGTON, D.C. 20024 (202) 554-2345
21
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I rulemaking or policymaking or what-have-you.
2 I think the results of the survey compel me to 3
refocus again on three issues.
It is the overtime, it y(-
4 is the retraining and our licensed operator population, 5
our requirements now for the second SRO in the control 6
room.
7 I think the staff comes out very strongly in 8
favor of continuing our present practice, which would be 9
to accept the industry survey of the five and six-shift 10 rotational schemes as being an acceptable method to 11 operate power plants safely.
12 COMMISSIONER GILINSKYs Well, I must say I am 13 certainly please& to see as many plants in.that category 0-14 as there appear to be, but the question we have to deal 15 with is to what extent are we willing to permit a lower 16 number of shif ts for whatever length of time is involved.
17 MR. ZWOLINSKI:
Certainly is a strike 18 situation occurred at a power plant and it was not going 19 to be resolved in a short term, a month, for example, 20 and I assume we would be on a three-shift rotation, the 21 Commission may want to look at how long*does one allow 22 that to progress without resolution.
I didn't focus the 23 presentation on those types of abnormalities.
[).
24 CONMISSIONER GILINSKY:
The overtime 25 restriction, it seems to me, doesn't amount to much.
ALDERSON REPORTING COMPANY. INC, 400 VIRGINIA AVE., S.W WASHINGTON, D.C. 20024 (202) 554 2345
22
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1 What it cones down to is that the man in charge has got 2
to sign and approve overtime and when he need it he just 3
approves it.
O 4
CH AIRMAN P ALLADINO:
Would'it be helpful to 5
just review what constraints you have now on the 6
operators?
7 MR. DENTONa I think there are the three that 8
John mentioned.
That is the overtime requirement 9
CRAIRMAN PALLADINos.And nobody works more 10 than 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> in one continuous ---
11 MR. ZWOLINSKIa Correct, or 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in a work 12 week.
13 COMMISSIONER AHEARNE4 Well, there are four, 14 at least as I am reading from 737.
15 MR. ZWOLINSKIa You have it in front of you.
16 CHAIRMAN PALLADINO:
Do you want to read them, 17 John?
18 COMMISSIONER AHEARNEa Well the four are:
19 An individual should not be permitted to work 20 more than 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> straight, not including shift-21 turnover time.
~
22 S e co n d, there should be a break of at least 12 23 hours2.662037e-4 days <br />0.00639 hours <br />3.80291e-5 weeks <br />8.7515e-6 months <br /> which can include shift turnover time between all
(
24 work periods.
25 Third, an individual should not work more than 1
l ALDERSON REPORTING COMPANY,INC, 400 VIRGINTA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
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1 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.
2 Fourth, an individual should not be required 3
to work more than 14 consecutive days without having two G'
4 consecutive days off.
5 Ihen it goes on to say that deviation can be 6
authorized by the plant manager or his deputy.
7 COMMISSIONER GILINSKYa And when they need 8
deviations they just authorize them.
9 MR. DENION:
I think we modified that since 10 that went out.
This caused a great deal of comment.
11 COMMISSIONER AHEARNEs This is the modified 12 version.
There vas a previous one, right, but it was 13 superseded.
14 MR. DENION:
That is one area for the need for 15 the training program to be an integral part for 16 operators as a second ---
17 CHAIRMAN PALLADIN0a How much tine do they i
18 spend in' training?
Is there any amount specified in 19 that?
20 MR. ZWOLINSKI Thera is not a time specified 21 by the Commission.
When the man sits for his 22 requalification exam and he doesn't do well, he is l
l 23 certainly put into a number of one-week courses to get
( )
24 him back up to an acceptable level.
If he does poorly 25 on his exas, they will give him immediate courses and i :
ALDERSON REPORTING COMPANY. INC.
400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
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1 take him off of shift' work.
2 CHAIRMAN PALLADINO:
Do we have any feel on 3
the average for what f raction of time the people are r /
e 4
spending on training?
5 MR. DENTON:
One shift is always in training.
6 CHAIRMAN PALLADINO So that is one-sixth.
7 MR. ZWOLINSKIa My understanding is it is 8
between one-fifth and one-sixth.
So that would be 9
something like 20 percent.
Now some utilities, if the 10 man scores 100 percent on his exam, still put him 11 through th e retraining program to focus, not necessarily 12 on requalification issuas, but on issues of the day that 13 have affected the nuclear power industry.
14 COMMISSIONER ROBERTSa Can you give me some 15 sort of feel on wha t sort of turnover there is, or can 16 you not make such a general statement?
17 HR. DENTON:
We can.
Do don't have anyone 18 from the' Licensing Branch down here today that keeps 19 that type of statistics.
20 MR. KRAMER:
We can get you that.
21 HR. REMICKs I have some statistics, it is 22 outdated now, but I remember back a few yea rs ago when 23 Paul Collins gave a paper and I was surprised.
For both l
(,,
24 an RO and an SRO, the average tenure was about four 25 years.
I don't know if that has changad, but the ALDERSON REPORTING COMPANY. INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345 i
25
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1 average tenure of an RO or SRO was about four years.
2 Now that meant that some of these people went on to 3
other positions, some RO's went on to SRO's and some 4
SRO's went on to management.
5 COMMISSIONER AHEARNE:
I have the same 6
recollection, it was a surprisingly high turnover.
7 MR. REMICK:
Yes.
8 MR. DENTON:
Then the third area, that is the 9
number of operators per shift, I think that is before 10 the Commission now.
11 COMMISSIONER AHEARNE:
Yes.
12 COMMISSIONER GILINSKY:
Do you know the extent 13 to which plant managers have approved deviations from k,-)
14 those guidelines or requirements?
15 ER. DENION:
I don't know right off.
16 COMMISSIONER AHEARNEs I don't think there is 17 any requirement.
They are not required to notify us.
18 Is that something that is ever checked or verified?
19 MR. DENTON:
There have been a couple of times 20 that I recall where the Regional Inspector would call l
l l
21 and we talked about what was going on, but it is more l
22 that the ICE inspector would check it if there is a i
23 problem.
In things like the Salem case, it was a
(
24 regional decision that they were adequately covered.
I 25 think by not having a requirement you give some ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W,. WASHINGTON, D.C. 20024 (202) 554-2345 1
26
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flexibility for handling these cases to make an on-site N.. /
2 judgment about the people there.
3 CHAIRMAN PALLADINOs Ihey are not required to
(,_).
v 4
co'me back and report extended deviations f rom the 5
guidelines?
6 NR. DENTON:
No.
7 This concludes our 30-minute presentation.
8 (Laughter.)
9 CHAIRMAN PALLADIN0s You know, that took~only 10 30 minutes even with interruptions. '
/
11 COMMISSIONER AHEARNE:
We have 286 in front of 12 us which is a rulemaking on staffing.
To what extent do 13 you believe the utility industry's positions that you J
14 have here would be modified by a choice of either of 15 these options?
Is it independent?
16 COMMISSIONER GILINSKY That is an interesting 17 point because I thought a number of the utilities were 18 not going to staff up to the extent we recommended after 19 THI for some time.
20 HR. DENTON:
I think John mentioned that there 21 were indications that in order to come onboard with the 22 two SRS's, there were indications they were dropping the 23 number of shifts temporarily.
([)
24 COMMISSIONER AHEA RNE:
Right, and wha t I am 25 asking is that you have two options here that you lay
(
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE, S.W., WASHINGTON D.C. 20024 (202) 554 2345
27
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1 out particularly focused on the SRO, and depending on 2
which way the Commission comes, do you see that as 3
d riving the utilities' commitment here?
You have got
_s 4
everybody by the end of this year will be at five and a 5
number you have saying that they are going towa rds six.
6 Your recommendation here in the paper, at least in the 7
charts, was that the Commission strongly endorsed going l
8 towards six.
9 NR. DENION:
I would no longer support that 10 recommendation.
11 MR. ZWOLINSKIs It was just policy statement.
12 MR. DENTON:
When we were talking about the 13 need for it, I wasn't sure what the results of the 14. survey would turn out to be, and I am really pragmatic 15 having seen the survey ---
16 COMMISSIONER AHEARNE:
But I think what you 17 are saying is that you are happy with the industry, the 18 bulk of them at five and some of them moving toward six, 19 and you are satisfied with that.
20 The point I an asking is that if we choose one 21 or the'other of your options in this other paper, do you 22 think that that will affect where the industry is?
Will 23 it lead, for example, to a number dropping back to four,
(.)
24 or would it reinstitute your recommendation of the 25 policy statement?
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400 VIRGINIA AVE., S.W., WASHINGTON D.C. 20024 (202) 554-2345
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1 ER. KRAMER4 Commissioner Ahearne, we had not 2
considered tha t in the draf ting of the proposed rules.
c 3
MR. ZWOLINSKIs I see the codifying of 4
SECY-82-286 as really the Commission endorsing the 5
second SRO and must of the industry has adopted that.
6 Nov what we are trying to do is put it into the formal 7
ruiemaking process rather than arm twisting and 8
technical specifications.
This is cleaning up our act a 9
little bit.
10 COMMISSIONER AHEARNE Are you saying that it it is at least your belief that if we vent for the second 12 RO in the rule that wouldn 't modify any of the utility 13 behavior?
14 MR. DENTON:
Well, I think the response ve 15 have gotten to the audit assumes that is what we were 16 going to do and that results in this temporary dip f rom 17 six to five.
18 COMMISSIONER AHEARNE:
I see.
19 MR. DENTON.
It might perturb a few 20 individuals, but most eveybody seems to be adopting 21 their own preferred staffing plans that fully meet our 22 requirements.
23 MR. ZWOLINSKIa Clearly if the Commission
()
24 vanted six shifts and so stated, the industry would go 25 to its training people and engin ee ring support people
\\v ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE S.W., WASHINGTON. D.C. 20024 (202) 554-2345
29
/
1 that have licenses and form that sixth shift.
The 2
licensed operator population is there at most facilities.
3 CHAIRMAN PALLADINO:
Harold, the requirements
(
4 tha t we have now, do you feel that they meet the 5
objectives that the staff felt need to be met with 6
regard to ha ving enough people without working them too 7
long?
8 MR. DENTON:
I feel they are met in a 9
sufficiently large f raction of all cases out there that 10 ve don't need to make a ruling.
I can't guarantee that 11 tomorrow there won 't be some ---
12 COMNISSIONER GILINSKY:
Isn't that what rules 13 are for?
k,I
-14 CHAIRMAN PALLADINO Ny point is if they met
~
15 these rules, would they have met all the objectives?
If 16 they are not meeting these rules, then we take a 17 different kind of action.
18 MR. DENTON:
I guess in my view five shifts 19 can fully meet our requirements for overtime and the 20 number of peopla in training.
21 CHAIRMAN PALLADINO:
What is in the back of my 22 mind is we don 't want to take over management's job 23 completely 24 (Laughter.)
25 CHAIRMAN PALLADIN0s
--- and we have certain ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W WASHINGTON. D.C. 20024 (202) 554-2345
30
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1 objectives and we want to make sure there are enough 2
people on the job, that they are not overworked and that 3
they are training.
Then af ter we have specified that, 4
lesve it to the utility to decide how many shif ts it 5
needs to do all those things.
6 Nov what I am saying is if they meet these 7
requirements, the 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, the 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> break, the 72 8
hours and seven days and 14 days and then at least two 9
days of f and training and so many on a shif t, would we 10 have achieved all the objectives that you felt needed to 11 be achieved?
12 MR. DENTON:
In my view, yes.
13 COMMISSIONER GILINSKY:
But we don't knov 14 whether they are meeting them.
15 CHAIRMAN PALLADINO:
That is a different 16 question.
17 COMMISSIONER GILINSKY They are not really 18 requirements.
It is just a line, and if you want to 19 exceed that line, you have got to get the manager's 20 signature.
That is all it is.
It is not like a l
21 requirement on the number of diesel generators.
You l
22 know, you can't exceed that with the manager signing a 23 piece of paper.
So it is a very different matter.
l
(;
24 CHAIRMAN PAL 1ADINO Well, somewhere if you 25 are going to have management you have got to have some e
s ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
31
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1 flexibility there.
What you want to make sure is that 2
they are exercising that responsibility in s 3
straightforward and effective manner.
4 HR. DENTON:
We can audit this area a year 5
from now and see if they are still meeting these 6
commitments.
My view is that they are and I prefer to 7
have the flexibility to deal with the unusual cases on a 8
case-by-case basis.
I think there have been cases in i
9 which we haven't agreed in the past that people could 10 safely operate and acted there.
I guess it is a matter 11 of style as to whether ypu want a rule of five or six 12 shifts or whether you think you need one or not.
13 COHNISSIONER GILINSKY Why should we
()
14 dif ferentis te this from say a requirement on batteries 15 or diesel generators?
16 MR. DENTON:
I guess, Commissioner, the only 17 reason I see 'the difference is that those things stay in 18 play for'four years.
They occasionally don 't work.
The 19 people problem and turnover in the company and 20 unexpected attrition or illness makes running and l
21 aeeting people requirements somewhat different.
I can 22 see a need for flexibility if the underlying functions 23 of those people are performed or not.
(}
24 COH5ISSIONER GILINSKY.
Well, by setting a t
25 requirement on shifts you still need a fair degree of ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
32
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1 flexibility as far as individuals go, but it means that 2
the company is forced to have a certain staff which 3
ought to go a long way to making sure of the fact that 4
most people vill not get overworked and so on.
5 CHAIBMAN PALLADINO:
But we have that when we 6
say how many people and what quality we want on each 7
shift, and when we give them the rules around which ---
8 COMMISSIONER GILINSKYa But those rules ---
9 CHAIRMAN PALLADINO That is what I was going 10 to say though.
You are saying we are act enforcing them.
11 COMMISSIONER GILINSKY:
Yes.
12 CHAIRMAN PALLADIN04 Maybe the better thing is 13 to enforce these rules rather than try to set another 14 rule up.
15 COMMISSIONER AHEARNEs But there is a 16 fundamental difference between those rules and what we 17 are talking about here.
Those rules are on hours people 18 work and'these are the number of complementing people, 19 although you can argue about what a shift is also.
20 COMMISSIONER GILINSKI There are various ways 21 to do this.
I just think that setting the number of 22 shifts is a simple way of doing it which still leaves a 23 fair degree of flexibility and it still allows for some
(
24 accommodation of special circumstances.
It means that 25 you are making sure that the conpany at the corporate C.
ALDERSON REPORTING COMPANY. INC.
400 VIRGINIA AVE., S.W WASHINGTON. D.C. 20024 (202) 554-2345
33
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1 level is going to have to budget for a certain staff, 2
and you are taking the burden of f the manager of the 3
f acility and putting it with his corporate management
,7~,
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4 and making sure they budget for an adequate operating 5
staff.
From then on it is his responsibility and he has 6
got to manage the people.
7 COMNISSIONER AHEARNE:
I would be a lot more 8
comfortable with doing that if I felt we really had 9
something more than.a feeling for what is the right
-10 number of shifts or even what is the right number of 11 hours1.273148e-4 days <br />0.00306 hours <br />1.818783e-5 weeks <br />4.1855e-6 months <br /> that people should work.
I an a little uneasy 12 about, in fact I am very uneasy about stepping in and 13 saying that we will decide how many shifts or here are
-l 14 the fixed number of hours that people should work based 15 upon the information that we have.
16 COHNISSIONER GILINSKYs Well, I thought 17 setting the number of shifts leaves more flexibility 18 than specifying hours per day.
l 19 COMMISSIONER AHEARNEa It does leave 20 flexibility, but, as you have described, it is taking 21 over a part of the management ---
22 COMMISSIONER GILINSKYs You are saying you
(
23 have got to budget this much for an operating staff.
([i 24 CHAIREAN PALLADINO:
I think you are saying 25 something different.
Maybe using shifts is a shorthand,
~%me ALDERSoN REPORTING CpMPANY,INC, 400 VIRGINIA AVE S.W., WASHINGTCN, D.C. 20024 (202) 554-2345
34
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(,_)
1 but I don't understand six shifts, unless you just have 2
a shif t that is just waiting.
3 COMMISSIONER GILINSKY :
Well, we ate not 4
talking about a specific number here.
S CHAIRMAN PALLADINO:
By the time you say how 6
many people should be on a shift ---
7 COMMISSIONER GILINSKY:
Well, the number could 8
be six, it could be five, it could be four or it could 9
be seven.
-10 CHAIRHAN PALLADINO:
When we pass the rule 11 that we acting on it will say "X"
number of operators, 12 "Y"
number of senior operators, and one shift supervisor.
13 COMMISSIONER GILINSKY:
Duplicated so many O
14 times.
15 CHAIRMAN PALLADINO:
And dup'li sted so many 16 times.
Now if you say six shifts, then you have to 17 precisely have six shift supervisors, if I interpret 18 your rule right.
And if one quits, then I am out of 19 compliance.
20 COMMISSIONER GILINSKYs It is just like if you 21 have diesel generators, if th e y d o n ' t w o rk ---
22 CHAIRIAM PALLADINO:
But the reason you had 23 the six was because you wanted one more than the minimum.
.[
24 COMMISSIONER GILINSKY:
Well, maybe they can 25 just set the minimum at five and recommend six.
You ALDERSON REPORTING COMPANY,INC, I
400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345
35 O
know, I am not arouine for a specific nunher here-
^
l 2
prudent mansger would make sure that he had enough 3
people over that line.so he doesn't get himself in a q
v 4
situation where he goes below the minimum.
5 CHAIRMAN PALLADIN0s Well, s prudent manager 6
would not try to micro-manage, and that is what I think 7
ve are trying to do.
We said here is the anximum number 8
of hours and here are the number of hours you have got 9
to have between breaks.
~
-10 COMMISSIONER GILINSKY That is why I don't -
'-~
11 like those rules.
12 CHAIRMAN PALLADINO:
I think they are 13 excellent rules, except that I think we are not them.
14 enforcing 15 COMMISSIONER GILINSKY Joe, you are talking 16 about us not getting involved in the details of 17 precisely how many hours each individual should work, 18 but you want to go ---
19 CHAIBMAN PALLADINO:
That is because we have 20 got them.
I don't want to add another one here on top
~
21 of them.
22 COMMISSIONER GILINSKYa Well, I would suggest 23 replacing these with a requirement on shifts.
That was mO 24 my point.
25 CHAIRMAN PALLADIN0s Then let them work it out.
1 v
ALDERSoN REPORTING COMPANY,INC, 400 'M AGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
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1 CONNISSIONER GILINSKYa Let them cort it out.
2 But I think if they have enough people, I assume they 3
will spread the work around and they won 't load up a v
4 small fraction of the work' force and let the others sit 5-around.
I t
6 CHAIRMAN PALLADIN0s Well, I guess my own view l
7 is I am not sure we have a problem.
8 COMMISSIONER GILINSKY:
Well, I think the 9
situation looks a lot better, I must say, than I 10 expected and I am pleased to see that.
But suppose we 11 were looking, just to get back to the example, batteries 12 or diesel generators, I don't think we would sa y well 13 most of them have got enough diesel generators so there 14 is no point in having a requirement.
15 COMMISSIONER AHEABNE:
No, but I think we 16 would on diesel generators come in with at least a 17 better either an historical base or an analysis to 18 justify why it is there ought to be a requirement on 19 diesel generators and we are not there yet.
At least I 20 don't think we are there yet on any of these.
21 We are soving slowly on the number of people 22 in the control, and I think we feel fairly comfortable 23 ve have got that.
We are moving very slowly on the
(
24 qualifications of those people whose numbers we have l
1 25 specified in the control room.
Then to move further to l
l ALDERSoN REPORTING COMPM4Y,INC.
400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
37
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I then say in addition how long shall those people be 2
allowed to work, which is either hours or shifts, I 3
think we are still farther away from.
At least I feel
()
4 that way.
5 COMMISSIONER GILINSKY Well, we are more or 6
less pretending that we have a require men t in that area.
7 COMMISSIONER AHEARNE:
Given advice.
8 CHAIRMAN PALLADINO:
When we come to the 9
number of people on shift, I presume that is going to be 10 m requirement.
11 COMMISSIONER GILINSKY:
No, that is a
.12-requirement.
I am talking about the number of hours ---
13 CHAIRMAN PALLADINO:
Well, that is more 14 comparable to your diesel generators or your-batteries.
15 COMMISSIONER GILINSKY:
No, I don't think so.
16 CHAIRMAN PALLADINO:
Well, if I have got to 17 have so many diesel generators available when I run the 18 plant, that is the same as how many I have got to'have.
19 COMMISSIONER GILINSKY:
Oh, in the control 20 room?
21 CHAIRMAN PALLADINO:
Yes.
22 COMMISSIONER GILINSKY:
Yes, I think that is s
23 right, but not when you say 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> per day.
-3
(,)
24 CHAIRMAN PALLADINO:
Oh, I ngree with you.
l 25 You don't work batteries that hard.
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ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
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38
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1 (Lauchter.)
2 COMMISSIONER GILINSKY:
Well, if you don't 3
(-)
feel there is a problem.
=
4 CHAIRMAN PALLADINO:
Let's ask the staff.
Do 5
rou feel there is a problem that we need to solve by 6
passing some policy or rule?
7 COMMISSIONER GILINSKY:
Well, let me ask you 8
this.
What happens if a plant goes down to three shifts 9
or two shif ts?
Do they notify somebody?
10 MR. DENTON:
What happens in real life is the 11 resident is the first person to know it.
I remember in 12 recent times the Salem experience and the Regional 13 Director ande some evaluation and calls us here and O
14 discusses his views on whether they can safety continue 15 or not, and we either support him or not.
So it is a 16 decision ande by the people close up to the facility who 17 know the specific individuals involved and their 18 capabilities rather than by a rigid system.
19 COMMISSIONER GILINSKY:
One of the things you 20 would be accomplishing by setting a requirement is that 21 you would be making sure that corporate ~mangement does 22 not slack off in providing enough funds and supporting 23 the individual plants and plant managers in this area.
es
1 24 If we don't care all that much, I don't know what will s,,
25 happen.
m ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE, S.W WASHINGTON, D.C. 20024 (202) 554 2345
39
(])
1 CON 5ISSIONER AHEARNE:
That is a 2
mischaracterization, Vic.
You can go ahead and say we 3
don't care, and maybe you have detailed information that gs Q.)
4 leads you to conclude the details.
I just have not seen 5
us with enough information that will enable me to reach 6
a conclusion of what that number should be that I can 7
say all right, utility, you must have no less than 8
this.
We don't have that.
9 CHAIBHAN PALLADINO:
Can I ask Harold a 10 question.
We keep saying these are not requirements, 11 the 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, et cetera.
Are they requirements or 12 aren't they requirements?
13 ER. DENTON:
You are speaking of the overtime 14 requirements?
l 15 CHAIBMAN PALLADINO:
Yes, the 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, the 72 1
16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> ---
17 (Laughter.)
18 HR. DENTON:
They are not Commission 19 regulations.
That is clear.
Many of the utilities have 20 connitted to abide by these in their letters to us.-
21 CHAIRMAN PALLADINO And once'they commit to 22 it does it have the force of regulation?
23 NR. DENTON:
Well, not the same force a
()
24 regulailon would have.
Then the inspector inspects that 25 obligation just like he does others, and if he doesn't l
ALDERSoN REPORTING COMPANY,INC.
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1 think they are honoring it, he can take action.
2 COBBISSIONER GILINSKYs But honoring it means 3
(
that they will not exceed it unless the plant manager or v
l 4
whoever the designated official is will approve it, 5
which means that they can exceed these limits.
i 6
CH AIRM AN P A1LADINO My experience is they do
(
7 it only under duress.
They don't do it as a routine 8
thing because your whole organization goes to pot when 9
rou do it.
- ER. DENTON:
I think we specifically had the 11 plant manager approve it so it would not be abused by a 12 lower level and it would have the highest level of 13 approval.
()
14 COMMISSIONER AHEARNE:
These are incorporated 15 in this sort of nebulous document, 737, which is a 16 letter.
Now the title of the le tter is " Post-IMI 17 Bequirements" and it is written to all licensees of 18 operating plants, for example, and it does say the 19 letter incorporates all TMI related iters approved for 20 implementation by the Commission.
So all the words and 21 flavor characterize it as though it were a requirement, 22 although as we know it is a little difficult to really 23 pin down exacty what is the legal action.
,3 1,./
24 As I recall on a number of other times when 25 this issue has come up either you, Harold, or E1D has U/
ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
m 61 1
pointed out or ICE that if they don't follow this, then 2
you would expect to issue them an order making then 3
follow it.
4 ER. DENTON:
If they deliberately didn't 5
follow it, then we would issue a show cause order and 6
that would then have the force ---
7' COMMISSIONER GILINSKYa But not following it 8
seans exceeding those limits without the manager's 9
approval.
That is what not following it means.
10 COREISSIONER AHEARNE Well, the whole 11 sentence says " Recognizing that circumstances may 12 arising requiring deviation from the above restrictions, 13 such deviations shall be authorized by the plant manager 14 or his deputy or higher' levels of management in 15 accordance with published procedures and with 16 appropriate documentation of the cause."
17 So that to follow this would mean that they, 18 if they are following it, that they are either living l
l 19 within those guidelines or else there is not only a 20 record of approval but a record of the cause of the 21 approval.
That is why I think it might be interesting 22 to find out whether we have ever checked any of those.
23 CHAIRNAN PALLADINO Do we check into th a t ?
j 24 Do we check whether or not the approval for exceptions l
25 is used?
t,/
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE, S.W., WASHINGTON, D.C. 20024 CO2) 554 2345
42 1
MR. DENTON:
I don't know whether that is a j
2 part of the routine inspection package or whether it is 3
audited by the region or not.
p 4
CHAIRMAN PALLADINO:
It might be well to do 5
some spot checking in some of the forthcoming 6
inspections.
7 Are there any other questions or expressions 8
of opinion?
9 (No response.)
10 CHAIRMAN PALLADINO:
I don't know whether I ~
11 got the sense of the Commission or not.
I would like to 12 go away knowing what we want to do.
13 Does the Commission'vish to take any steps to 14 develop a policy or a rule on the number of shifts?
15 COMMISSIONER AHEARNE:
Not at this time.
16 00H5ISSIONER ROBERTS:
I wouldn't.
17 COMMISSIONER GILINSKY:
I guess I would.
18 CHAIRMAN PALLADINO:
One, two, three "No" and
(
19 you say "Yes."
Then I would suspect that we not do 20 that, that we not make any policy or rule.
l l
21 I do think though it would be" appropriate in 22 some of the forthcoming or future inspections that some 23 spot checking be made of the extent to which the 7be 24 exception authority might be abused or how it is being 25 used.
ALDERSoN REPORTING COMPANY. INC, 400 VIRGINIA AVE., S.W WASHINGTON, D.C. 20024 (202) 554 2345
43
([)
1 COMMISSIONER AHEl.RNE:
That would probably be 2
an SRM to EDO for relay to the regions.
3 CHAIRMAN PALLADINO Where is staff?
Oh, gg s.
4 there he is.
Okay, he heard it.
5 (Secretary Chilk nodded positively from the 6
back of the room.)
l 7
CHAIRMAN PALLADINO:
Any other items we should 8
cover on this point?
i 9
(No response.) CHAIRMAN PALLADINO:
Okay.
I note we started 11 on time and I think we ending ahead of time.
12 COMMISSIONER ROBERTS:
I hope you are setting 13 a precedent.
14 (Laughter.)
15 COMMISSIONER AHEARNEa I would like to also 16 comment that it is good for once for the staff to have 17 come having done a survey and found that things are 18 better than they thought.
l 19 COMMISSIONER GILINSKY That was good to 1
l 20 discover.
1 21 CHAIRMAN *PALLADINO Well, it"may be showing l
22 they recognize requirements, too.
23 Thank you.
We will stand adjourned.
()
24 (Whereupon, at 3:05 p.m.,
the meeting l
25 adjourned.)
,S ss' l
I ALDERSON REPORTING COMPANY. INC.
400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345
8 l
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COMMISSION MEETING is the sattar cf:. PUBLIC MEETING -
Brieking'on MiniEimt Ntznber of Shift.3 Baquired at Cperating Frdctors CaC4 Of F "ccett 1351 July 21, 1982
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QCCk2C llMber:
1 FlzCe of Pecceeding.:
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DRAFT 7/8/82 l %
PORP05s C
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REGARDING THE NUMBER OF SHIFTS EMPLOYED FOR VARIOUS OPERATING MODES AT OPERATING FACILITIES.
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Minimum Number of Shifts Required at Operating Reactors 7/21 es
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5 CKGR00ND TOTAL NUMBER OF SHIFTS DRIVEN BY PAST INDUSTRY PRACTICE AND NRC CONCERNS NO REGULATIONS NO REGULATORY 6UIDES NO BRANCH IECHNICAL POSITIONS l
NOT IN TECHNICAL SPECIFICATIONS e
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FIVE SHIFT OPERATION WITH RELIEF EVOLVING
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NUMBER NuMsER OF OF SHIFTS USED FACILITIES UNITS 3 SHIFTS PLUS 1
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FACILITIES ON 5 SHIFTS (CONT.)
KEWAUNEE LACROSSE MAINE YANKEE l
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0YSTER CREEK PALISADES PEACH BOTTOM 2 & 3 PILGRIM 1 POINT BEACH 1 & 2 QUAD CITIES 1 & 2 RANCHO SECO SALEM 1 & 2 SAN ONOFRE 1
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SECUOYAH 1 & 2 SURRY l & 2 IROJAN VERMONT YANKEE YANKEE ROWE ZION 1 & 2 i
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FACILITIES ON 6 SHIFTS CRYSTAL RIVER FITZPATRICK
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6 SHIFTS PROS ASSURES COMPLETE COMPLEMENT OF LICENSED STAFF ADDRESSES RETRAINING AND OVERTIME CONCERNS ALLOWS INTERACTION BETWEEN OPERATIONAL STAFF AND TECHNICAL STAFF CONS INDUSTRY MAY NEED TO ATTIRACT MORE-CANDIDATES INTO R0/SR0 TRAINING PROGRAM e
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DIRECT NRR TO ISSUE A LETTER TO ALL LICENSEES AND APPLICANTS
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CONTINUE PRESENT PRACTISE OVERTIME RETRAINING i
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