ML20087L239

Responds to Request for Tech Spec Change to Limit Amount of Overtime Worked by Plant Staff Members Performing safety- Related Functions.Amend to Tech Specs Delayed Pending Adoption of Commission Proposed Rule

ML20087L239
Person / Time
Site:	Point Beach
Issue date:	03/19/1984
From:	Fay C WISCONSIN ELECTRIC POWER CO.
To:	Harold Denton, John Miller Office of Nuclear Reactor Regulation
References
RTR-NUREG-0737, RTR-NUREG-737 TAC-54559, TAC-54560, NUDOCS 8403270098
Download: ML20087L239 (2)

Text

WhSC00 Sin Electnc rowca coursur 231 W. MICHIGAN, P.O. BOX 2046. MILWAUKEE, WI 53201 March 19, 1984 Mr.

H.

R.

Denton, Director Office of Nuclear Reactor Regulation U.

S.

NUCLEAR REGULATORY COMMISSION Washington, D.

C.

20555 Attention:

Mr.

J.

R. Miller, Chief Operating Reactors, Branch 3 Gentlemen:

DOCKETS 50-266 AND 50-301 TECHNICAL SPECIFICATION TO LIMIT OVERTIME POINT BEACH NUCLEAR PLANT, UhiTS 1 AND 2 In your amendment approval letter dated December 28, 1983, you reiterated the request transmitted by NRC Generic Letter 82-16 dated September 20, 1982 that Wisconsin Electric Power Company propose an addition to the Point Beach Nuclear Plant Technical Specifications which would limit the amount of overtime worked by plant staff members performing safety-related functions in accordance with the NRC Policy Statement on working L

hours.

As you know, we noted in our response to Generic Letter 82-16 datcd December 15, 1982 that these restrictions are presently addressed by administrative procedures.

Mr.

R. A. Clark's letter dated December 2, 1981 had acknowledged that these plant procedures adequately address the overtime guidance.

Our procedures wer?

Ap~

subsequently revised to comply with the changes in this guidance as promulgated in NRC Generic Letter 82-12 dated June 15, 1982.

We are, in summary, in agreement with the NRC Policy Statement and g:11 dance concerning staff overtime and working hours.

Notwithstanding our conformance with this policy, we believe that this topic is not an appropriate item for documentation in the plant Technical Specifications.

The Commission has published a proposed rule concerning technical specifications for nuclear power reactors in 47 Federal Register 13369.

This proposed rule was prompted by the increased volume and detail of technical specifications and is an attempt to reduce the resultant paperwork burden for both licensees and th: NRC staff due to the large number (OW lf 84032700'90 840319 PDR ADOCK 05000266 p

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2-March 19, 1934 Mr.:H.:R.'Denton:

of proposed: change requests that must be processed.

With

'the proposed' rule,fthe NRC would modify the categories of required specifications to those items which focus directly ion the aspects of reactor operation that are important to the Lpublic' health'and safety and would define a new. category of o

requirements that'would be of lesser immediate importance to "sefety than technical specifications.-.This would permit greater

~

-flexibility,to both the NRC and. licensees 1in p..

-? sing changes

.toLthis11atter category of requirements.

We

-a'the policy on limiting-staff' overtime would properly tr. w-go this latter category of issues with lesser'immediate in g &le to safety-and is not appropriate' for inclusion in plan-

..nnical specifi-g

~

' cations.

Although the NRC has not, as yet, acted on this proposed rule,7we believe it is appropriate to consider this request for

+7

'an' overtime technical specification in-light of this proposed 1 rule.

Licensees are already required by their technical specifications to; operate their nuclecr plants in accordance with approved procedures.- Should a licensee schedule overtime hours contrary to approved procedures, the - N RC, including the

Resident-Inspectors, already have' adequate authority and precedent to enforce this overtime ~ policy.

' In light of the pending ' Commission position on technical

specificationsand our conformance with the overtime policy statement Tinf our: plant procedures, we propose to ' delay amending our operating l licenses and revising our technical specifications in anticipation

,-of the adoption of the Commission'<s proposed rule on-technical

~

specification' content.

m Very truly yours, m

Y Vice-President-Nuclear. Power

' j f a

C.LW. Fay Copy to NRC. Resident Inspector

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