Comment (4) of Doug Foster on FR Doc # E9-28380

I am an on-shift SRO at a dual unit site. My plant has gone through an outage with the Fitness for Duty Fatigue Rule work hours in place. I know firsthand the negative impact that the Fitness for Duty work hour rule change has had on my station. This petition, specifically dealing with a "site outage" vs. "unit outage" and addressing the time outage work hour rules begin and end would greatly benefit the site and operating crews during outages. The current rule concerning when outage work hour rules begin essentially eliminates the preparation week most sites have adopted just before an outage. Establishing “supercrews” a week prior to the outage will now be difficult, if not impossible. The term supercrew is the concept of combining the entire Operations department into two crews, one for days and one for nights. Also the time frame after the breaker is closed at the end of the outage, often the busiest time for Operations, also falls outside the extended work hours allowed for the outage period. Getting into and out of an outage is now more difficult. Additionally the “outage unit” is a term only used in the Regulatory Guide 5.73. The term is not formally defined, but means that the unit “disconnected from the grid” is the only unit able to use the outage work hour limitations. Simply stated, the non-outage unit(s) at multi-unit sites must maintain a predetermined number of individuals under the normal hour limitations. More simply stated the outage personnel and non-outage personnel will be working different schedules. This will not impact single unit sites, or multi-unit sites that don’t share personnel during outages, but it can have a huge impact on two-unit sites, especially those that share a common control room. The supercrew concept cannot stay intact the way it had been implemented at most sites since the supercrew concept encompasses the operating unit. More licensed personnel are required to support the non-outage unit, reducing the number of licensed personnel available to work the outage. Both of these issues have caused a change in the very successful past practice of supercrews for outage manpower utilization. Not only as PROS President but as an on-shift SRO, I recommend the Commission vote in favor of this rule change.