ML20198R892

SER Accepting Licensee Proposed Amend to TSs to Delete Reference to NRC Policy Re Plant Staff Working Hours & Require Administrative Controls to Limit Working Hours to Be Acceptable

ML20198R892
Person / Time
Site:	Perry
Issue date:	01/07/1999
From:	NRC (Affiliation Not Assigned)
To:
Shared Package
ML20198R886	List: ML20198R883 ML20198R892
References
GL-82-12, NUDOCS 9901110079
Download: ML20198R892 (1)

Text

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r Safetv Evaluation

, Perry Nuclear Power Plant Technical Soecification Amendment Docket No.: 50-440 l l

1. INTRODUCTION By letters dated September 8,1997 and October 27,1998, FirstEnergy Nuclear Operating Company requested approval to amend Technical Specification 5.2.2.e, " Organization -

Unit Staff," for Perry Nu;Iear Power Station. The proposed changes to the unit Technical Specifications would replace the reference to the NRC's policy concerning plant staff working hours (Generic Letter 82-12) with requirements for (1) administrative controls that ensure adequate shif t coverage is maintained without heavy use of overtime for individuals, (2) advance authorization by the Plant Manager or a designee for deviations from the working hour guidelines, and (3) monthly reviews by the Plant Manager or a designee to ensure that excessive hours have not been assigned.

2. EVALUATION On February 11,1982, the NRC published (47 FR 7352) the " Policy on Factors Causing Fatigue of Operating Personnel at Nuclear Reactors." In June 1982, the NRC revised the policy and subsequently disseminated the revision in Generic Letter 82-12, " Nuclear Plant Staff Working Hours," which recommended that licensees incorporate specific working hour limits in plant technical specifications to minimize the potential for personnel errors resulting from fatigue. The staff subsequently determined that few events at U.S. nuclear plants have been attributed to inadequate control of working hours and that control of working hours through administrative procedures provides reasonable assurance that personnel overtime will not jeopardize safe plant operation. Control of overtime through administrative procedures is consistent with Action Item I.A.1.3.1, " Limit Overtime," of NUREG-0737, " Clarification of TMI Action Plan Requirements." Specific working hour limits are not otherwise required to be included in technical specifications under 10 CFR 50.36(c)(5).

In addition to the requirement for administrative controls to limit the working hours of unit staff who perform safety related functions, the proposed amendments require advance authorization of deviations from the working hour guidelines and monthly reviews of overtime use to ensure that excessive hours have not been assigned. These requirements are consistent with guidance provided in Generic Letter 83-02, "NUREG-0737 Technical Specifications," and NUREG-1434, Rev.1, " Standard Technical Specifications General Electric Plants, BWR/6."

3. CONCLUSION The staff concludes that the specific controls for working hours of reactor plant staff can be described in a licensee procedure and that a licensee's established procedure control processes will provide sufficient control for changes to that procedure. Accordingly, the staff finds the proposed amendment to the Technical Specifications to de'ete the reference to the NRC's policy concerning plant staff working hours and require administrative controls to limit working hours to be acceptable. The proposed amendments requiring advance authorization of deviations from the working hour guidelines and monthly reviews of overtime use are consistent with current NRC guidance for the control of working hours and are accotoingly found acceptable.

Principle Reviewer:

David R. Desaulniers, NRR/DRCH/HOHB, 415-1043

= Attachment 1 9901110079 990107 PDR ADOCK 05000440 P PDR

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