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Kamishan O. Martin, Human Factors Engineer Office of Nuclear Reactor Regulation

Utility Workers Union of America, AFL-CIO Power for America Conference April 23, 2009 Las Vegas, Nevada. Kamishan O. Martin, Human Factors Engineer Office of Nuclear Reactor Regulation. Overview. Policy/Rulemaking History and Background Fatigue Effects and Contributing Factors

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Kamishan O. Martin, Human Factors Engineer Office of Nuclear Reactor Regulation

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  1. Utility Workers Union of America, AFL-CIOPower for America ConferenceApril 23, 2009Las Vegas, Nevada Kamishan O. Martin, Human Factors Engineer Office of Nuclear Reactor Regulation

  2. Overview • Policy/Rulemaking History and Background • Fatigue Effects and Contributing Factors • Managing Fatigue in Rule Provisions • Implementation Dates and Guidance • Questions

  3. History - Background • 1982 NRC published GL 82-12, Policy on Worker Fatigue • 1991 NRC issued IN 91-36, Nuclear Plant Staff Working Hours • 1999 NRC received concerns from Congress and UCS • 2001 NRC staff reviewed adequacy of policy implementation • 2002 Commission approved rulemaking • 2002-2008 public meetings held on draft requirements and implementation development • 2008 Final Rule Published

  4. History - Background • Guidance not clear and not prescriptive • Use of waivers not clearly limited • Cumulative fatigue not effectively addressed • Only addresses fatigue from work hours

  5. Fatigue Effects and Contributing Factors Fatigue is defined as a degradation in a person’s cognitive and motor functioning resulting from inadequate rest. Acute Fatigue means fatigue from causes occurring in the past 24 hours, such as restricted sleep, sustained wakefulness and task demands. Cumulative Fatigue means the increase in fatigue over consecutive sleep-wake periods resulting from inadequate rest.

  6. Fatigue Effects and Contributing Factors • Occurs Before sleep onset • Effects comparable to blood alcohol concentrations that are prohibited in Part 26 • Impairs attention, communication skills, decision making, teamwork

  7. Fatigue Effects and Contributing Factors Conditions that contribute to fatigue are prevalent in the nuclear industry 7

  8. What is the answer? Sleep The requirements accommodate napping.

  9. Major Rule Provisions: Work hour controls Periodic performance based assessments Training Self-declarations Waivers Behavioral observation Fatigue assessments Annual reporting Addresses Contributors to Fatigue including: Tasks – work hour limits based on duties performed Rest – Requires days off and permits napping Rule Provisions

  10. Rule Provisions Objectives: Establishing clear and enforceable requirements for the management of worker fatigue to strengthen the effectiveness of FFD programs Strengthen the effectiveness of FFD programs at nuclear power plants Incorporate existing security work hours limits Provide the rights and responsibilities of licensees and workers

  11. Rule Provisions 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.

  12. Rule ProvisionsApplicability Only to operating plants (not construction sites) 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”

  13. Rule ProvisionsWork Hour Controls Required for: • Maintenance (Risk-significant only) • Operations (Risk-significant only) • Chemistry (Emergency Response only) • Health Physics (Emergency Response only) • Fire Brigade (the individual responsible for knowing effects of fire and suppressants on safe shutdown capability) • Security Force (armed) • Individuals who direct risk significant maintenance or operations.

  14. 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 from 24 to 26 hours in any 48-hour period Increase min. break period between work periods from 8 hours to 10 hours Limit waivers to conditions necessary to prevent or mitigate conditions adverse to safety or security Added Minimum Days Off (MDO) requirements

  15. Rule ProvisionsMinimum Day Off Requirements (MDOs) 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

  16. Rule ProvisionsMDOs During Non-Outages In each shift cycle 26.205(d)(3) *Averaged over the shift cycle, from one to six weeks long. Days off must be distributed to provide at least 34 hours off in any 9-day period

  17. Rule ProvisionsMDOs During Outages Periods are successive, not rolling Applies to every shift: 8, 10 or 12-hr Days off still must be distributed to provide at least 34 hours off in any 9-day period

  18. Rule ProvisionsMDO Outage • Individuals will be limited to 60 consecutive days of outage scheduling • 7 day extensions will be allowed for each 7-day period during outage individual works not more than 48 hours • Individuals are subject to outage controls, “while working on outage activities”

  19. Rule ProvisionsWaivers • 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

  20. Rule Provisions Waivers

  21. Rule Provisions Fatigue Assessments • For-cause • Post-event • Follow-up • Self-declaration • Applicable to all personnel subject to the fitness-for-duty program

  22. Rule Provisions Self Declaration A statement that you are not able to safely or competently perform your duties because of fatigue

  23. Rule Provisions Self Declaration • Requires that licensee procedures describe: • Rights and responsibilities • Controls and conditions for permitting or requiring individuals to perform work following a self-declaration • Process to be followed if an individual disagrees with the results of a fatigue assessment

  24. Implementation • Full compliance required within 18 months of (March 31, 2008) rule publication date • Training Completed

  25. Implementation Guidance 25 • 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

  26. FAQ Processhttp://www.nrc.gov/reactors/operating/ops-experience/fitness-for-duty-programs/contact-us.html • E-mail is sent to FFD Working Group • Consensus reached on issue (not official regulatory position) • Respond via e-mail at earliest convenience

  27. Thank You Questions ?

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