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10 CFR Part 26 Subpart IManaging Fatigue

Kamishan MartinHuman Factors Engineering

June 23, 2010HPRCT conference

Overview

• Background / Purpose• Rule Provisions • Implementation• Questions

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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

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

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

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• 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”

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Rule ProvisionsApplicability

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

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Rule ProvisionsApplicability

Rule ProvisionsWork 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 ProvisionWork 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 ProvisionWork Hour Controls

MDO Requirements

*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

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

Outage Day off Requirements

Periods are successive, not rollingApplies to every shift: 8, 10 or 12-hr

Group Days off* Maintenance 26.4(a)(4) 1 in 7 Operations 26.4(a)(1) 3 in 15

Security 26.4(a)(5) 4 in 15

Rule ProvisionWork Hour Controls

• 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 ProvisionWaivers

• For-cause • Post-event• Follow-up• Self-declaration• Constraints on who can perform them

– Trained– No conflicts of interest

Rule ProvisionFatigue Assessments

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

Rule ProvisionSelf Declarations

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• 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

Rule ProvisionRecordkeeping and Reporting

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.

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• 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

ImplementationGuidance 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

ImplementationGuidance Documents

• 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

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ImplementationOngoing Activities

Questions???????

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