ML20207B594
| ML20207B594 | |
| Person / Time | |
|---|---|
| Issue date: | 07/20/1988 |
| From: | Kerr W Advisory Committee on Reactor Safeguards |
| To: | Zech L NRC COMMISSION (OCM) |
| References | |
| ACRS-R-1313, NUDOCS 8808020393 | |
| Download: ML20207B594 (2) | |
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UNITED STATES o,,
NUCLEAR REGULATORY COMMISSION j
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- 1 ADVISOMY COMMITTEE ON REACTOR SAFEGUARDS
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wAsmotou, o. c, mu July 20, 1988 1
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The Honorable Lando W. Zech, Jr.
Chairman U.S. Nuclear Regulatory Comissicn Washingten D.C. 20555 Cear Chairman Zech:
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SUBJECT:
REPORT ON PROPOSED REVISED POLICY STATEMENT ON NUCLEAR POWER PLANT STAFF WORKING HOURS 1
Curing the 330th meeting cf the Advisory Committee on Reactor Safe-l 2
guards, July 14-16, 1988, we discussed the proposed revised policy l
statement on nuclear power plant staff working hours.
During our j
meeting, we had the benefit of discussions with the NRC staff and of the documents listed as refererces for this letter.
t Although we telieve that revised guidance on nuclear plant working hours should be issued for public coment, we do not recomend that the version of the prcrosed revised policy statement that we reviewed should f
be issued, for the reasons which follow.
The staff confuses what ccnstitutes a policy statement and what consti-i tutes a rule or regulation.
On the one hand, the staff, in addressing CRGR questions (Enclosure 4 to the referenced draf t Comission Paper) l makes stateronts such as (1) the policy statement revises present cuidance on shif t scheduling and overtire by adding guidance on...; (2) l the revised policy statement is net a rulet (3) the revised policy statener.t will apply to nuclear power plent licensees on a voluntary basis; and (4) nothing is required.
On the other hand, the draf t Comission Paper, the sutrary of and background to the policy statement, and the policy staterent itself are replete with such stateeents as (1) administrative procedures shall be develeped; (2) the procedures shall apply to the plant operating staff; (3) )the utility must specify limith (4) the plant manager rust approve; (5 the documentation required by 1615 policy statement; and (6) limits that shall not be exceeded.
Such statements of rendatory action are not appropriate for a policy state-ment that is to provide guidance to licensees to use on a voluntary basis.
Further, there are major inconsistencies among statements made in this draf t Comission Paper and statements made in the sumary of, the back-ground to, and the policy statement itself.
To mention a few of these inconsistencies, the sumary states that (1) to exceed the first set of limits, the plant maneger's approval must be documented and retrievable, whereas the policy statement indicates that the plant manager's approval
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l The Hcnorable Lando W. Zech, Jr. July 20, 1988 l
t should be separately dccurented and that these documents should be retrievable and (2) the plant ranager must explain the circumstances that require this deviation, whereas the poTicy statement indicates that the circunstances that required deviation from the guidelines should be explained.
Such confusion ard inconsistency in a document proposed to be issued for j
public coment will result in responses not focused on the real issues of the revised guidance.
We believe for these reasons, the version of l
i the policy statement provided to us for review is not ready to be published fcr public coment.
The staff indicates that the mandatory
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action staterents will be uniformly and consistently renoved, f
ke do have a concern th6t for some personnel not engaged in routine shif t work, the recomendations in the policy statement may be over-restrictive.
If so, we trust that during the public coment period l
Inowledgeable and experienced experts will provide more specific cor-l rents for consideratien in the final formulation of the policy state-ment.
In the staff's presentation, they gave numerous references that provide the bases for the revised limits and recomendations indicated in the proposed policy statement. We believe these references should be listed in the Federal Register notice in order that the bases for the revisien can be carefully examined, tuditional coments by ACRS Member Harold W. Lewis are presented below, l
Sincerely.
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William Kerr Chairman j
Additional Cemrents by ACR$ Member Harold W. Lewis i
I find the assertion that "nothing is required" somewhat empty. A l
Comission Policy Staten2ent carries weight, and experience suggests that l
a licensee who ignores it incurs a certain risk.
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Reference:
Draft Proposed Comission Policy Statement en Nuclear Pcwer Plant Staff
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Working Hours with enclosures, received with memorandum dated June 17, i
1988, from J. W. Roe, hRR, to R. F. Fraley, ACRS.
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