10 CFR Part 26, Subpart I
Managing Fatigue
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
Overview
Policy/Rulemaking History and Background
Fatigue Effects and Contributing Factors
Managing Fatigue in Rule Provisions
Implementation Dates and Guidance
Questions
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
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
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.
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
Fatigue Effects and
Contributing Factors
Conditions that contribute to fatigue are prevalent in the nuclear industry
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What is the answer?
Sleep
The requirements accommodate napping.
Rule Provisions
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
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
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.
Rule Provisions
Applicability
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”
Rule Provisions
Work 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.
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
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 (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
Rule Provisions
MDOs During Non-Outages
In each shift cycle
(i)
(ii)
(iv)
(iii)
(v)
26.205(d)(3)
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 34 hours
off in any 9-day period
Rule Provisions
MDOs During Outages
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
Days off still must be distributed to provide
at least 34 hours off in any 9-day period
Rule Provisions
MDO Outage
Individuals will be limited to 60 consecutive
days of outage scheduling
7 day extensions will be allowed for each 7day period during outage individual works not
more than 48 hours
Individuals are subject to outage controls,
“while working on outage activities”
Rule Provisions
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 Provisions
Waivers
Who Determines?
Waiver Needed to:
Operations Shift
Manager
Mitigate or prevent a
condition adverse to
safety
Security Shift Manager
Maintain site security
Site Senior-level
Mitigate or prevent a
Manager with requisite condition adverse to
authority
safety and/or to
maintain site security
Rule Provisions
Fatigue Assessments
For-cause
Post-event
Follow-up
Self-declaration
Applicable to all personnel subject to the
fitness-for-duty program
Rule Provisions
Self Declaration
A statement that you are not able to safely
or competently perform your duties because
of fatigue
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
Implementation
Full compliance required within 18 months
of (March 31, 2008) rule publication date
Training Completed
Implementation 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
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FAQ Process
http://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
Thank You
Questions
?