10 CFR Part 26, Subpart I10 CFR Part 26, Subpart I

Managing FatigueManaging Fatigue10 CFR Part 26, Subpart I10 CFR Part 26, Subpart I

Managing FatigueManaging Fatigue

Kamishan O. Martin, Human Factors EngineerKamishan O. Martin, Human Factors Engineer

Office of Nuclear Reactor RegulationOffice of Nuclear Reactor Regulation

Kamishan O. Martin, Human Factors EngineerKamishan O. Martin, Human Factors Engineer

Office of Nuclear Reactor RegulationOffice of Nuclear Reactor Regulation

Utility Workers Union of America, AFL-CIOUtility Workers Union of America, AFL-CIOPower for America ConferencePower for America Conference

April 23, 2009April 23, 2009Las Vegas, NevadaLas Vegas, Nevada

Utility Workers Union of America, AFL-CIOUtility Workers Union of America, AFL-CIOPower for America ConferencePower for America Conference

April 23, 2009April 23, 2009Las Vegas, NevadaLas Vegas, Nevada

OverviewOverviewPolicy/Rulemaking History and BackgroundFatigue Effects and Contributing FactorsManaging Fatigue in Rule ProvisionsImplementation Dates and GuidanceQuestions

Policy/Rulemaking History and BackgroundFatigue Effects and Contributing FactorsManaging Fatigue in Rule ProvisionsImplementation Dates and GuidanceQuestions

History - BackgroundHistory - Background1982 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

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

History - BackgroundHistory - Background

Guidance not clear and not prescriptiveUse of waivers not clearly limitedCumulative fatigue not effectively addressedOnly addresses fatigue from work hours

Guidance not clear and not prescriptiveUse of waivers not clearly limitedCumulative fatigue not effectively addressedOnly addresses fatigue from work hours

Fatigue Effects and Contributing FactorsFatigue 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.

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.

Fatigue Effects and Contributing FactorsFatigue Effects and Contributing Factors

Occurs Before sleep onset Effects comparable to blood alcohol concentrations that are prohibited in Part 26Impairs attention, communication skills, decision making, teamwork

Occurs Before sleep onset Effects comparable to blood alcohol concentrations that are prohibited in Part 26Impairs attention, communication skills, decision making, teamwork

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Fatigue Effects and Fatigue Effects and Contributing Factors Contributing Factors Fatigue Effects and Fatigue Effects and Contributing Factors Contributing Factors

Conditions that contribute to fatigue are prevalent in the nuclear industryConditions that contribute to fatigue are prevalent in the nuclear industry

What is the answer?What is the answer?

SleepThe requirements accommodate napping.

Rule ProvisionsRule Provisions

Major Rule Provisions:Work hour controlsPeriodic performance

based assessmentsTrainingSelf-declarationsWaiversBehavioral observationFatigue assessmentsAnnual reporting

Major Rule Provisions:Work hour controlsPeriodic performance

based assessmentsTrainingSelf-declarationsWaiversBehavioral observationFatigue assessmentsAnnual reporting

Addresses Contributors to Fatigue including:Tasks – work hour

limits based on duties performed

Rest – Requires days off and permits napping

Addresses Contributors to Fatigue including:Tasks – work hour

limits based on duties performed

Rest – Requires days off and permits napping

Rule ProvisionsRule ProvisionsObjectives:

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 plantsIncorporate existing security work hours limitsProvide the rights and responsibilities of licensees and workers

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 plantsIncorporate existing security work hours limitsProvide the rights and responsibilities of licensees and workers

Rule ProvisionsRule ProvisionsPerformance 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.

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.

Rule Provisions ApplicabilityApplicability

Rule Provisions ApplicabilityApplicability

Only to operating plants (not construction sites)Fatigue management program elements apply to anyone with unescorted accessWork hour limits, MDO requirements and rest break requirements in §26.205 apply subset of individuals referred to as “covered workers”

Only to operating plants (not construction sites)Fatigue management program elements apply to anyone with unescorted accessWork hour limits, MDO requirements and rest break requirements in §26.205 apply subset of individuals referred to as “covered workers”

Rule Provisions Work Hour Controls Required forWork Hour Controls Required for::

Rule Provisions Work Hour Controls Required forWork 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.

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.

Rule Provisions Work Hour ControlsWork Hour ControlsRule Provisions Work Hour ControlsWork Hour Controls

Retain maximum work hour limits of:16 hours in any 24-hour period72 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

Retain maximum work hour limits of:16 hours in any 24-hour period72 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

Rule Provisions Minimum Day Off Requirements Minimum Day Off Requirements

(MDOs)(MDOs)

Rule Provisions Minimum Day Off Requirements Minimum Day Off Requirements

(MDOs)(MDOs)Vary according to:

Plant state (operating or outage)Shift duration (8, 10, or 12 hours)Job duties

maintenanceoperations, health physics, chemistry, fire brigadesecurity

Vary according to:Plant state (operating or outage)Shift duration (8, 10, or 12 hours)Job duties

maintenanceoperations, health physics, chemistry, fire brigadesecurity

Rule Provisions MDOs During Non-OutagesMDOs During Non-Outages

Rule Provisions MDOs During Non-OutagesMDOs 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

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

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

Rule Provisions MDOs During OutagesMDOs During OutagesRule Provisions

MDOs During OutagesMDOs During Outages

Periods are successive, not rollingApplies to every shift: 8, 10 or 12-hrDays off still must be distributed to provide at least 34 hours off in any 9-day period

Periods are successive, not rollingApplies to every shift: 8, 10 or 12-hrDays off still must be distributed to provide at least 34 hours off in any 9-day period

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 Provisions MDO OutageMDO Outage

Rule Provisions MDO OutageMDO 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”

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”

Rule Provisions WaiversWaivers

Rule Provisions WaiversWaivers

Waivers only allowed:To mitigate or prevent a condition adverse to safetyTo maintain the security of the facility

Face-to-Face Fatigue assessment required to approve waiverReview of work hours + time of day work would be performed also considered in assessment

Waivers only allowed:To mitigate or prevent a condition adverse to safetyTo maintain the security of the facility

Face-to-Face Fatigue assessment required to approve waiverReview of work hours + time of day work would be performed also considered in assessment

Rule Provisions WaiversWaivers

Rule Provisions WaiversWaivers

Who Who Determines?Determines?

WaiverWaiver Needed Needed to:to:

Operations Shift Manager

Mitigate or prevent a condition adverse to safety

Security Shift Manager

Maintain site security

Site Senior-level Manager with requisite authority

Mitigate or prevent a condition adverse to safety and/or to maintain site security

For-cause Post-eventFollow-upSelf-declarationApplicable to all personnel subject to the fitness-for-duty program

For-cause Post-eventFollow-upSelf-declarationApplicable to all personnel subject to the fitness-for-duty program

Rule Provisions Fatigue AssessmentsFatigue AssessmentsRule Provisions Fatigue AssessmentsFatigue Assessments

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

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

Rule Provisions Self DeclarationSelf Declaration

Rule Provisions Self DeclarationSelf Declaration

Requires that licensee procedures describe:

Rights and responsibilities Controls and conditions for permitting or requiring individuals to perform work following a self-declarationProcess to be followed if an individual disagrees with the results of a fatigue assessment

Requires that licensee procedures describe:

Rights and responsibilities Controls and conditions for permitting or requiring individuals to perform work following a self-declarationProcess to be followed if an individual disagrees with the results of a fatigue assessment

Rule Provisions Self DeclarationSelf Declaration

Rule Provisions Self DeclarationSelf Declaration

ImplementationImplementation

Full compliance required within 18 months of (March 31, 2008) rule publication dateTraining Completed

Full compliance required within 18 months of (March 31, 2008) rule publication dateTraining Completed

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Implementation GuidanceImplementation Guidance

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

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

FAQ Processhttp://www.nrc.gov/reactors/operating/ops-experience/fitness-for-duty-programs/http://www.nrc.gov/reactors/operating/ops-experience/fitness-for-duty-programs/

contact-us.htmlcontact-us.html

FAQ Processhttp://www.nrc.gov/reactors/operating/ops-experience/fitness-for-duty-programs/http://www.nrc.gov/reactors/operating/ops-experience/fitness-for-duty-programs/

contact-us.htmlcontact-us.html

E-mail is sent to FFD Working GroupConsensus reached on issue (not official

regulatory position)Respond via e-mail at earliest convenience

E-mail is sent to FFD Working GroupConsensus reached on issue (not official

regulatory position)Respond via e-mail at earliest convenience

Thank YouThank You

Questions?

Questions?