ML20244C785

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Clarifies Term Deputy Plant Manager Used in Generic Ltr 82-12.Only Senior Mgt Officials Should Be Able to Authorize Major Deviations from Overtime Guidance of NRC Policy Statement on Working Hours
ML20244C785
Person / Time
Issue date: 10/28/1983
From: Eisenhut D
Office of Nuclear Reactor Regulation
To: Norelius C
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML16342B348 List: ... further results
References
FOIA-87-121 GL-82-12, NUDOCS 8311290326
Download: ML20244C785 (2)


Text

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-MEMORANDUM FOR: C. E. Norelius, Director Division of Project and Resident Programs U..  !

Region III FROM: . Darrell G. Eisenhut, Director Division of Licensing Office of Nuclear Reactor Regulation

SUBJECT:

CLARIFICATION OF THE TERM " DEPUTY PLANT MANAGER" AS USED IN GENERIC LETTER 82-12 Your memorandum of September 6,1983, requested clarificaticn of the intent of the statement contained in Generic Letter 82-12 that deviations from the.

working hour guidelines shall be authorized by the plant manager, or his l deputy, or higher levels of management.

As used in Generic Letter 82-12, the term deputy was intended to mean the l principal assistant to the plant manager. In most cases, this individual would be the Assistant Plant Manager. The intent of the guidance in Generic Letter 82-12 is that only senior management officials should be able to authorize major deviations from the overtime guidance of the Commission's policy statement on working hours, enclosed with Generic Letter 82-12.

The wording of your memorandum, and that of W. G. Gu,ldemond's August 5,1983, memorandum which you enclosed, leads us to believe that there also may be other problems in interpretation of the working hour guidance in addition to l the meaning of the word deputy.

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l The goal of the NRC is that each plant be staffed with sufficient numbers of '

personnel so that there should be no need for a licensee to resort to more or less routine use of overtime. That is, there should be adequate numbers of properly trained personnel to handle normal work recuirements, including training, while working normal eight-hour days and 40-hour weeks. Regardless of the normal staffing levels, however, situations may arise wnere overtime  ;

l must be used to assure adequate shift coverage. For example, an operator may i fail to report for his assigned shift, necessitating that an operator from the previous shift be held over to provide coverage. Similarly, maintenance work on a safety system or component may be in progress at the end of a normal shift and the licensee may deem it preferable to complete the effort by using the same workers on overtime rather than to change crews for the

. cemainder of the job. These types of situations are provided for in the

. overtime guidance wherein, on a temporary basis, an individual may be i permitted to work up to 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> straight, but with the other limitations as stated in the policy. In such cases, we would expect authorization for such overtime to be handled by the appropriate supervisors in accordance with

, licensee procedures, with timeJy reperts to plant management to assure I nianagement awareness of the status of overtime usage.

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' In addition, there may be very unusual cases where overtime in e* cess of the

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l temporary deviation guidelines may be needed (i.e., mere than 161 hours0.00186 days <br />0.0447 hours <br />2.662037e-4 weeks <br />6.12605e-5 months <br /> i straight more than 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> in a 24-hour period, more than 24. hours in-a 48-hour period, or'more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />' in a seven day period). Such~ instances should be very few in number and should be handled by senior plant management. For this reason, the guidance specifies that authorization for such overtime must be obtained from the plant manager or his deputy, or from )

higher levels Lof. management. l Darrell G. Eisenhut, Director Division of Licensing Office of Nuclear Reactor Regulation cc: H. Denton-T. Murley, Region I J. O'Reilly, Region ~II J. Collins, Region:IV J. Martin, Region V J. Taylor, IE e

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