ML20084F249

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Restates Position Re Procedure AP 0036, Shift Staffing. Procedure Presently Applies NUREG-0737 Restrictions Only to Listed Shift Positions or Individuals
ML20084F249
Person / Time
Site: Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date: 05/01/1984
From: Murphy W
VERMONT YANKEE NUCLEAR POWER CORP.
To: Vassallo D
Office of Nuclear Reactor Regulation
References
RTR-NUREG-0737, RTR-NUREG-737 FVY-84-39, GL-82-12, NUDOCS 8405040034
Download: ML20084F249 (2)


Text

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T$RMONT YANKEE NUCLEAR POWER CORPORATION FVY 84-39 RD 5. Box 169, Ferry Road, Brattleboro, VT 05301 g g,Ly,g p

ENGINEERING OFFICE yv 1671 WORCESTER ROAD FRAMINGHAM, MASSACHUSETTS 01701 May 1, 1984 Tetersons sir-e72-aioo U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention:

Office of Nuclear Reactor Regulation Mr. Domenic B. Vassallo, Chief Operating Reactors Branch No. 2 Division of Licensing

References:

a)

License No. DPR-28 (Docket No. 50/271) b)

Letter, USNRC to Licensees, dated June 15, 1982 c)

Letter, USNRC to Licensees, dated March 7, 1983 d)

Letter, VYNPC to USNRC, dated October 12, 1982

Dear Sir:

Subject:

Shift Staffing During the normal review cycle for plant procedure AP 0036, " Shift Staffing", a comment was made by one of the reviewers regarding the application of the procedure and its degree of compliance with NRC guidelines.

It was recognized that similar comments might be raised by the NRC. To limit con-fusion, this letter is being sent to explicitly restate our position with regard to the subject NUREG 0737 item.

At the present time procedure AP 0036 " Shift Staffing" applies the NUREG 0737 overtime restrictions only to the following shift positions and/or individuals:

Shift Supervisor, Supervisory Control Room Operator, Control Room Operator, Auxiliary Operator, Shift Engineers, Health Physics-Technicians, and Security Officers.

During extended periods at cold shutdown conditions, the overtime limits are applied only to those individuals assigned duty in tt+

Control Room.

In addition, guidance is provided for management notifim. tion should the minimum shift staffing requirements not be met.

At_no time was our intent to infer that AP 0036 applied to any other position not listed above.

In our response to Generic Letter 82-12, we informed the NRC tt at it was our position that the administrative procedures in affect, including AP 0033, when combined with proper management supervitary at'ention for the positions not covered in AP 0036, implemented a policy which met the intent of the NRC's.

guidelines regarding the restriction of wiertime.

e405040034 840501

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PDR ADOCK 05000271 P

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U.S. Nuclear Regulatory Commission Ray 1,1984 Page 2 VERMONT YANKEE NUCLEAR POWER CORPORATION It should be noted that our procedure has been subject to inspection by NRC regional inspectors and deemed acceptable.

We trust that this letter clarifies our position; should you have any questions, please do not hestitate to contact us.

Very truly yours, VERMONT YANKEE NUCLEAR POWER CORPORATION W'

Warren P. Murphy Vice President and Manager of Operations WPM /dm ij

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