ML20235D091
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i HEUCRANLQ1 FOR:
D. G. Eisenu'uu, Director, Division of Licensing, h~rdi FROM:
C. E. Norelius, Director, Division of Project and Resident Progra=s
SUBJECT:
REQUEST FOR ASSISTANCE CLARIFICATION OF GE.NT.RTC LETTER 82-12 " NUCLEAR POWER PLANT STAFF WORKING H01RS" Generic' Letter 82-12, which gives specific guidelines concerning the contrcl of overtirne of plant personnel, includes the statement:
" Recognizing that very unusual circu:nstances may arise requiring I
deviation from the above guidelines, such deviations shall be authorized by the plant manager, or his deputy, or higher' levels of management."
The intent of this statement apparently indicates that an awareness by senior management 2s required prior to any deviations from :ne established guidelines l
for overt;me. ho ever, inclusion of the plant manager's deputy as having the authority to approve deviations of this type, seems to' contradict this pos2-
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tion. The term deputy could be considered any person which the plant manager may des 2gnate to act in this capacity. This creates the po,ssibility that the responsibility to authorize deviations from the overtime guidelines could be delegated to low levels of supervisors, e.g. Shift Superv: sors.
We have attached for your reference a memorandum from our Resicent Inspecter a:.
LaSalle County, documenting practices at that station which we'do not believe meet the intent of the Generic Letter or TMI Task Action Item :.A.I.3.
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J 8707100051 870701 PDR FOIA WILLIAM 87-121 PDR i
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e D. G. Eisenhut 2
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A clear definition of the minimum level of mar.arement required to therize deviations from guidelines on the use of overtime at nuclear power plants is required. Your assistance in resolving this issue would be appreciated.
d i ML C. E. Norelius, Director Division of Project and Resident Programs At t a c hmen t :
As stated cc:
V. G. Guldemond, Senior Resident Inspector, LaSalle County Station i
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