10 CFR Part 26 Subpart I Managing Fatigue

Kamishan Martin Human Factors Engineering June 23, 2010 HPRCT conference

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Overview

• Background / Purpose • Rule Provisions • Implementation • Questions 2

Background

• 1982 - NRC published GL 82-12, Policy on Worker Fatigue • 1991 - NRC issued IN 91-36, Nuclear Plant Staff Working Hours • 2001 - NRC staff reviewed adequacy of policy implementation • 2002 - Commission approved rulemaking • 2008 - Final Rule Published • 2009 - Licensees implemented measures for compliance 3

Background

• A degradation in a person’s cognitive and motor functioning resulting from inadequate rest.

• Acute Fatigue – fatigue from causes occurring in the past 24 hours, such as restricted sleep, sustained wakefulness and task demands.

• Cumulative Fatigue – increase in fatigue over consecutive sleep wake periods resulting from inadequate rest.

Background

• Purpose: – Establishing clear and enforceable requirements for the management of worker fatigue to strengthen the effectiveness of FFD programs – Codify orders limiting security work hours – Strengthen the effectiveness of FFD programs at nuclear power plants 5

Rule Provisions

• Applicability • Work Hour Controls • Waivers and Exceptions • Self Declarations • Fatigue Assessments 6

Rule Provisions

Applicability

• Only to operating plants • Fatigue management program elements apply to anyone with unescorted access • Work hour limits, MDO requirements and rest break requirements in § 26.205 apply subset of individuals referred to as “covered workers” 7

Rule Provisions

Applicability

• Maintenance • Operations • Chemistry • Health Physics • Fire Brigade • Security Force • Individuals who directs these activities 8

Rule Provisions

Work Hour Controls

• Retain maximum work hour limits of: – 16 hours in any 24-hour period – 72 hours in any 7-day period • Increase maximum work hour limits – 24 to 26 hours in any 48-hour period • Increase min. break period between work periods from 8 hours to 10 hours • Limit waivers use conditions • Added Minimum Days Off (MDO) requirements

Rule Provision

Work Hour Controls

• MDO Requirements Vary According to: – Plant state (operating or outage) – Shift duration (8, 10, or 12 hours) – Job duties • maintenance • operations, health physics, chemistry, fire brigade • security

Rule Provision

Work Hour Controls

MDO Requirements (i) (ii) (iv) (iii) (v) Shift 8 hr 10 hr 12 hr maintenance 12 hr operations 12 hr security Days off per week* 1 2 2 2.5 3

*Averaged over the shift cycle, from one to six weeks long.

Days off must be distributed to provide at least 1 day off in any 9-day period

Rule Provision

Work Hour Controls

Outage Day off Requirements Group Maintenance 26.4(a)(4) Operations 26.4(a)(1) Security 26.4(a)(5) Days off* 1 in 7 3 in 15 4 in 15 Periods are successive, not rolling Applies to every shift: 8, 10 or 12-hr

Rule Provision

Waivers

• Waivers only allowed: – To mitigate or prevent a condition adverse to safety – To maintain the security of the facility • Face-to-Face Fatigue assessment required to approve waiver • Review of work hours + time of day work would be performed also considered in assessment

Rule Provision

Fatigue Assessments

• For-cause • Post-event • Follow-up • Self-declaration • Constraints on who can perform them – Trained – No conflicts of interest

Rule Provision

Self Declarations

A statement to your supervisor that you are not able to safely or competently perform your duties because of fatigue

Rule Provision

Recordkeeping and Reporting

• Establishes recordkeeping requirements for licensees to retain specified records • Requires licensees to report to the NRC certain data related to their fatigue management programs as part of the annual FFD program performance report 16

Rule Provision

• Performance Based – Licensees shall schedule the work hours of individuals who are subject to this section consistent with the objective of preventing impairment from fatigue due to the duration, frequency, or sequencing of successive shifts.

Implementation

Guidance Documents

• Reg. Guide 5.73, “Fatigue Management for Nuclear Power Plant Personnel” endorses: • NEI 06-11, Rev 1 – “Managing Personnel Fatigue at Nuclear Power Reactor Sites”

http://www.nrc.gov/reactors/operating/ops-experience/fitness-for-duty.html

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Implementation

Guidance Documents

• E-mail is sent to FFD Working Group • Consensus reached on issue (not official regulatory position) • Respond via e-mail at earliest convenience

http://www.nrc.gov/reactors/operating/ops-experience/fitness-for-duty-programs/contact-us.html

Implementation

Ongoing Activities

• NRR has established a Review panel to review any findings related to the fatigue rule. • Temporary Instruction (TI) inspection of Subpart I requirement & Inspection Procedures in Manual Chapter • Engaging the industry and soliciting feedback concerning implementation concerns 20

Questions

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