10 CFR Part 26 Subpart I
Managing Fatigue
Kamishan Martin
Human Factors Engineering
June 23, 2010
HPRCT conference
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Overview
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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
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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 sleepwake 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
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Applicability
Work Hour Controls
Waivers and Exceptions
Self Declarations
Fatigue Assessments
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Rule Provisions
Applicability
• 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 Provisions
Applicability
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Maintenance
Operations
Chemistry
Health Physics
Fire Brigade
Security Force
Individuals who directs these activities
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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
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
Rule Provision
Work Hour Controls
MDO Requirements
(i)
(ii)
(iv)
(iii)
(v)
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 1 day off in any 9-day period
Rule Provision
Work Hour Controls
Outage Day off Requirements
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
Rule Provision
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 Provision
Fatigue Assessments
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For-cause
Post-event
Follow-up
Self-declaration
Constraints on who can perform them
– Trained
– No conflicts of interest
Rule Provision
Self Declarations
A statement to your supervisor that you
are not able to safely or competently
perform your duties because of fatigue
Rule Provision
Recordkeeping and Reporting
• 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
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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.
Implementation
Guidance Documents
• 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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Implementation
Guidance 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
Implementation
Ongoing Activities
• 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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Questions
???????
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