1. 1 10 CFR Part 26 Subpart I Managing Fatigue Kamishan Martin Human Factors Engineering June 23, 2010 HPRCT conference

2. Overview Background / Purpose Rule Provisions Implementation Questions 2

3. 3 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

4. 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.

5. 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

6. Rule Provisions Applicability Work Hour Controls Waivers and Exceptions Self Declarations Fatigue Assessments 6

7. 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 Applicability Rule Provisions Applicability

8. Maintenance Operations Chemistry Health Physics Fire Brigade Security Force Individuals who directs these activities 8 Applicability Rule Provisions Applicability

9. Work Hour Controls 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

10. Work Hour Controls 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

11. Work Hour Controls Rule Provision Work 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

12. Outage Day off Requirements Periods are successive, not rolling Applies to every shift: 8, 10 or 12-hr Work Hour Controls Rule Provision Work Hour Controls

13. 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 Waivers Rule Provision Waivers

14. For-cause Post-event Follow-up Self-declaration Constraints on who can perform them –Trained –No conflicts of interest Fatigue Assessments Rule Provision Fatigue Assessments

15. A statement to your supervisor that you are not able to safely or competently perform your duties because of fatigue Self Declarations Rule Provision Self Declarations

16. 16 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 Recordkeeping and Reporting Rule Provision Recordkeeping and Reporting

17. 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.

18. 18 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 Guidance Documents Implementation Guidance Documents

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

20. 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 Ongoing Activities Implementation Ongoing Activities

21. Questions ??????? 21