ML20135H706
| ML20135H706 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 09/20/1985 |
| From: | Cooney M PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Thompson H Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-1.A.1.3, TASK-TM NUDOCS 8509240148 | |
| Download: ML20135H706 (3) | |
Text
PHILADELPHIA ELECTRIC COMPANY 23O1 MARKET STREET f
P.O. BOX 8699 PHILADELPHIA. PA.19101 (2is) set-soro
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September 20, 1985 Docket Nos. 50-277 l
50-278
[
Mr. Hugh L.
Thompson, Jr., Director Division of Licensing U.S. Nuclear Regulatory Commission Washington, D.C.
20555
SUBJECT:
Peach Bottom Atomic Power Station Overtime Work Limits
REFERENCE:
1)
Correspondence dated March 31, 1981 S.
L. Daltroff (PECo) to D.
G. Eisenhut (NRC) 2)
Correspondence dated March 24, 1982 S. L. Daltroff (PECo) to D.
G. Eisenhut (NRC)
Dear Mr. Thompson:
This letter is to inform you that we have revised the Peach Bottom overtime policy for key maintenance, construction and testing personnel to establish consistency with the overtime policy for other plant personnel and the NRC's overtime guidance published at 47 Fed. Reg., page 7352 (February 18, 1982).
The original overtime policy commitment for Peach Bottom personnel was described in reference 1 and was developed in response to the guidance presented in NUREG-0737, Item I.A.l.3.1.
Subsequently, the NRC issued a new overtime policy, described in the Federal Register previously referenced.
In reference 2, we informed the NRC of our plans to apply the new NRC overtime policy to shift operating personnel, and health physics and chemistry technicians.
We have since expanded the application of the new overtime policy to include key maintenance, construction, and testing personnel who perform safety-related functions.
8509240148 850920 PDR ADOCK 05000277 I
.g Q
Mr. Hugh L. Thompson, Jr.
September 20, 1985 Page 2 The previous overtime policy for the maintenance, construction, and testing personnel was as follows:
1.
1.
An individual shall not be scheduled in advance to work more than 12 consecutive hours (excluding meal' periods),
nor more than 14 consecutive-days.
~
2.
If circumstances arise which require an individual to
. work more than 12 consecutive hours, such work shall'be authorized by the individual's supervisor, in accordance with approved procedures, and with appropriate documentation of the cause.
The new overtime policy for these personnel specifies i '
the following:
l.
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 /> straight (excluding shift turnover time).
2.
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, nor 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).
3.-
A break of at least eight hours should be allowed j.
between work periods.(including shi~ft turnover time).
4.
The use of overtime should be considered on an
_ individual basis and not for the entire staff on a shift.
4 Deviations.from these overtime. limits can be authorized by the individual's employing officer or a designated. alternate.
The new-policy permits more flexibility in the _
application.of the overtime limits without1 increasing.the total i,
' number'of hours. worked.over o two-day and one-week period.
i Therefore,.the objective of preventing plant personnel 1from performing' safety-related functions while in a. fatigue condition is still met..The'new policy conforms to the NRC' criteria and
{
. establishes ' uniform requirements for all personnelieubject to the 4
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-3 Nr.-Hugh L. Thompson, Jr.
September 20, 1985 Page 3 overtime work limits,. thereby resulting in a more effective administration of the overtime _ policy.
Should you have any questions regarding this matter, please do not hesitate to contact us.
Ver truly yours, f
cc:.
T. P. Johnson, Site Inspector
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