ML13256A386
| ML13256A386 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 09/12/2013 |
| From: | V Sreenivas Plant Licensing Branch II |
| To: | Shaub T Dominion Generation |
| References | |
| Download: ML13256A386 (5) | |
Text
1 NRR-PMDAPEm Resource From:
Sreenivas, V Sent:
Thursday, September 12, 2013 3:02 PM To:
Tom Shaub
Subject:
FW: North Anna Annual Fatigue Report Clarification Request Attachments:
Fatigue Form - Final for CY2012 Use.pdf; 26 203 e Page 260 from FRN Column Format.pdf; 26 717 Page 266 from FRN Column Format.pdf As a part of our analysis of annual reports, we need some clarifying information concerning data submitted in some of the Dominions CY2011 Fitness for Duty (FFD) fatigue management reporting forms.
Background on Fatigue Management Reporting:
The regulations which address the information required to be reported concerning Subpart I of Part 26 (fatigue management & work hour controls) is explicitly written in the rule text as stated in §26.717 and
§26.203(e). As for the format, the licensee can submit a hard copy of the information or use our electronic information exchange (EIE) that the NRC has developed to handle the reporting requirements. While the EIE portal may be easier and better for both the NRC and the licensee, there is no requirement saying they have to use our EIE. To request a certificate and more information necessary to use the EIE portal for reporting requirements they can e-mail FitnessForDuty.Resource@nrc.gov and ask for a digital certificate so that they can use our system Attached a blank reporting form and the pertinent rule text pages as published in FRN.
Description of the specific data discrepancies and/or data needs for each facility:
Clarification 1: The report states yes that waivers were issued during the reporting period.
However, no waivers are indicated in the tables Request: Please confirm whether waivers were issued during the reporting period Please let me know if you have any questions. If necessary we can schedule a phone call if they have questions or respond by 9/30/13. Also, please note, the purpose of this data request is to verify that the form was filled out properly and to get clarification for analyzing all the data received from the licensees concerning this rule, it is NOT to assess the licensee or for enforcement purposes.
Hearing Identifier:
NRR_PMDA Email Number:
833 Mail Envelope Properties (V.Sreenivas@nrc.gov20130912150200)
Subject:
FW: North Anna Annual Fatigue Report Clarification Request Sent Date:
9/12/2013 3:02:04 PM Received Date:
9/12/2013 3:02:00 PM From:
Sreenivas, V Created By:
V.Sreenivas@nrc.gov Recipients:
"Tom Shaub" <tom.shaub@dom.com>
Tracking Status: None Post Office:
Files Size Date & Time MESSAGE 1925 9/12/2013 3:02:00 PM Fatigue Form - Final for CY2012 Use.pdf 2440226 26 203 e Page 260 from FRN Column Format.pdf 55179 26 717 Page 266 from FRN Column Format.pdf 58616 Options Priority:
Standard Return Notification:
No Reply Requested:
No Sensitivity:
Normal Expiration Date:
Recipients Received:
NRC FFD Program Performance Data Reporting System Annual Fatigue Reporting Form for the EIE General Submission Portal Period of Report Please Select 10 CFR Part 26, Subpart I - Managing Fatigue Summary of Waiver Issuance - 26.203(e)(1)(i-ii)
Exceeded 16 work hrs in any 24 hr period Daily Work Hours 26.205(d)(1)
Number of Waivers Issued Operating or on-site directing of the operations of systems,as described in 26.4(a)(1)
Operating Outage (days 1-60)
Exceeded 26 work hrs in any 48 hr period Exceeded 72 work hrs in any 7 day period Performing health physics or chemistry duties, as described in 26.4(a)(2)
Operating Outage (days 1-60)
Performing duties of a fire brigade member, as described in 26.4(a)(3)
- Operating Outage (days 1-60)
Performing maintenance or onsite direction of maintenance, as described in 26.4(a)(4)
Operating Outage (days 1-60)
Performing security duties, as described in 26.4(a)(5)
Operating Outage (days 1-60)
Outage Total (days 1-60)
(Calculated)
Combined Total (Calculated)
Less than 10 hr break b/t successive work periods (or 8 hr break accommodating scheduled transition b/t shifts)
Rest Breaks 26.205(d)(2)
Less than 34 hr break in any 9 day period Minimum Days Off Per Shift Cycle 26.205(d)(3)
Average of less than 1 day off per week for 8-hour shifts Average of less than 2 days off per week for 10-hour shifts Average of less than 2.5 days off per week for 12-hour shifts Average of less than 2 days off per week for 12-hour maintenance shifts Average of less than 3 days off per week for 12-hour security shifts Minimum Days Off for Outage Activities (during first 60 days of outage) 26.205(d)(4) and 26.205(d)(5)
Less than 3 days off per successive 15-day period 26.205.(d)(4)
Less than 1 day off per 7-day period for maintenance personnel 26.205.(d)(4)
Less than 4 days off per successive 15-day period for security personnel 26.205.(d)(5)
Total
- NOTE: For individuals performing fire brigade duties and other duties, please count them only under the fire brigade column. Do not double count these individuals.
1 Number of Waivers 2
3 Operating or on-site directing of the operations of systems, as described in 26.4(a)(1) 4 5
6 7
8 Performing health physics or chemistry duties as described in 26.4(a)(2)
- NOTE: For individuals performing fire brigade duties and other duties, please count them only under the fire brigade column. Do not double count these individuals.
9 10 11 - 20 More than 20 Total Employees Issued Waivers (Calculated)
Most Waivers Provided to a Single Individual Distribution of Waivers for Individuals in Each Category - 26.203(e)(1)(iii)
Number of Employees Issued Waivers
[Note: Even if no waivers were issued for a given column, please enter a value (e.g., 0) in at least one of the cells in the column]
Performing duties of a fire brigade member as described in 26.4(a)(3)
- Performing maintenance or onsite directing of maintenance as described in 26.4(a)(4)
Performing security duties as described in 26.4(a)(5)
Summary of Corrective Action - 26.203(e)(2) (as applicable)
Analysis of Waiver Assessment Data: (Limit 10,000 characters)
Analysis of Fatigue Assessment Data: (Limit 10,000 characters)
Summary and Status of Corrective Actions: (Limit 10,000 characters)
==
Conclusions:==
(Limit 10,000 characters)
Print this Report Save to Local PC Today is:
Nov 5, 2012 Work Hour Controls Annual Fatigue Results Form (version 1.4.0 - Nov 5, 2012)
Was this facility in an outage for any part of the reporting period? (Yes / No)
Please Select Did any single site outage last more than 60 days in total? (Yes / No)
Please Select Did any of the first 60 days of an outage occur during the reporting period? (Yes / No)
Please Select Did any of the outage days after day 60 occur during the reporting period? (Yes / No)
Please Select Outage Total (after day 60)
(Calculated)
Outage (after day 60)
Outage (after day 60)
Outage (after day 60)
Outage (after day 60)
Outage (after day 60)
Note:
- 1) Use Adobe Reader 8 or later for this form to work properly.
- 2) Hold your mouse over a form field to view additional information.
Operating Total (Calculated)
Submission Update - check this box only if this is an update to a previous submission.
Select Facility Please Select Person(s) Responsible for Information Provided Company Email Address First Name Position Title Position Title First Name Last Name Last Name Company Email Address Person 1 (required):
Person 2 (optional):
Final Step (Required) - NRC will consider this form authentic in accordance with 26.11 only when the Validate & Lock button has been selected and all errors (i.e., those highlighted in red) have been corrected. The Validate & Lock button will change to Locked after the data validation process has been successfully completed and the form is ready for submission.
Validate & Lock Form Locked On:
Did your facility issue any waivers in the reporting period? (Yes / No)
Please Select 54 hour6.25e-4 days <br />0.015 hours <br />8.928571e-5 weeks <br />2.0547e-5 months <br /> maximum average Alternate to Minimum Days Off 26.205(d)(7)
General Comments (optional) (Limit 10,000 characters)
17224 Federal Register / Vol. 73, No. 62 / Monday, March 31, 2008 / Rules and Regulations Subpart IManaging Fatigue
§ 26.201 Applicability.
The requirements in this subpart apply to the licensees and other entities identified in § 26.3(a), and, if applicable, (c) and (d). The requirements in
§§ 26.203 and 26.211 apply to the individuals identified in § 26.4 (a) through (c). In addition, the requirements in § 26.205 through
§ 26.209 apply to the individuals identified in § 26.4(a).
§ 26.203 General provisions.
(a) Policy. Licensees shall establish a policy for the management of fatigue for all individuals who are subject to the licensees FFD program and incorporate it into the written policy required in
§ 26.27(b).
(b) Procedures. In addition to the procedures required in § 26.27(c),
licensees shall develop, implement, and maintain procedures that (1) Describe the process to be followed when any individual identified in § 26.4(a) through (c) makes a self-declaration that he or she is not fit to safely and competently perform his or her duties for any part of a working tour as a result of fatigue. The procedure must (i) Describe the individuals and licensees rights and responsibilities related to self-declaration; (ii) Describe requirements for establishing controls and conditions under which an individual may be permitted or required to perform work after that individual declares that he or she is not fit due to fatigue; and (iii) Describe the process to be followed if the individual disagrees with the results of a fatigue assessment that is required under § 26.211(a)(2);
(2) Describe the process for implementing the controls required under § 26.205 for the individuals who are performing the duties listed in
§ 26.4(a);
(3) Describe the process to be followed in conducting fatigue assessments under § 26.211; and (4) Describe the disciplinary actions that the licensee may impose on an individual following a fatigue assessment, and the conditions and considerations for taking those disciplinary actions.
(c) Training and examinations.
Licensees shall add the following KAs to the content of the training that is required in § 26.29(a) and the comprehensive examination required in
§ 26.29(b):
(1) Knowledge of the contributors to worker fatigue, circadian variations in alertness and performance, indications and risk factors for common sleep disorders, shiftwork strategies for obtaining adequate rest, and the effective use of fatigue countermeasures; and (2) Ability to identify symptoms of worker fatigue and contributors to decreased alertness in the workplace.
(d) Recordkeeping. Licensees shall retain the following records for at least 3 years or until the completion of all related legal proceedings, whichever is later:
(1) Records of work hours for individuals who are subject to the work hour controls in § 26.205; (2) Records of shift schedules and shift cycles of individuals who are subject to the work hour controls in
§ 26.205; (3) The documentation of waivers that is required in § 26.207(a)(4), including the bases for granting the waivers; (4) The documentation of work hour reviews that is required in § 26.205(e)(3) and (e)(4); and (5) The documentation of fatigue assessments that is required in
§ 26.211(g).
(e) Reporting. Licensees shall include the following information in a standard format in the annual FFD program performance report required under
§ 26.717:
(1) A summary for each nuclear power plant site of all instances during the previous calendar year when the licensee waived the work hour controls specified in § 26.205(d)(1) through (d)(5)(i) for individuals described in
§ 26.4(a). The summary must include only those waivers under which work was performed. If it was necessary to waive more than one work hour control during any single extended work period, the summary of instances must include each of the work hour controls that were waived during the period. For each category of individuals specified in
§ 26.4(a), the licensee shall report (i) The number of instances when each applicable work hour control specified in § 26.205(d)(1)(i) through (d)(1)(iii), (d)(2)(i) and (d)(2)(ii), and (d)(3)(i) through (d)(3)(v) was waived for individuals not working on outage activities; (ii) The number of instances when each applicable work hour control specified in § 26.205(d)(1)(i) through (d)(1)(iii), (d)(2)(i) and (d)(2)(ii), (d)(3)(i) through (d)(3)(v), and (d)(4) and (d)(5)(i) was waived for individuals working on outage activities; and (iii) A summary that shows the distribution of waiver use among the individuals within each category of individuals identified in § 26.4(a) (e.g.,
a table that shows the number of individuals who received only one waiver during the reporting period, the number of individuals who received a total of two waivers during the reporting period).
(2) A summary of corrective actions, if any, resulting from the analyses of these data, including fatigue assessments.
(f) Audits. Licensees shall audit the management of worker fatigue as required by § 26.41.
§ 26.205 Work hours.
(a) Individuals subject to work hour controls. Any individual who performs duties identified in § 26.4(a)(1) through (a)(5) shall be subject to the requirements of this section.
(b) Calculating work hours. For the purposes of this section, a licensee shall calculate the work hours of individuals who are subject to this section as the amount of time the individuals perform duties for the licensee. Except as permitted by paragraphs (b)(1) through (b)(5) of this section, the calculated work hours must include all time performing duties for the licensee, including all within-shift break times and rest periods during which there are no reasonable opportunities or accommodations appropriate for restorative sleep.
(1) Shift turnover. Licensees may exclude shift turnover from the calculation of an individuals work hours. Shift turnover includes only those activities that are necessary to safely transfer information and responsibilities between two or more individuals between shifts. Shift turnover activities may include, but are not limited to, discussions of the status of plant equipment, and the status of ongoing activities, such as extended tests of safety systems and components.
Licensees may not exclude work hours worked during turnovers between individuals within a shift period due to rotations or relief within a shift.
Activities that licensees may not exclude from work hours calculations also include, but are not limited to, shift holdovers to cover for late arrivals of incoming shift members; early arrivals of individuals for meetings, training, or pre-shift briefings for special evolutions; and holdovers for interviews needed for event investigations.
(2) Within-shift break and rest periods. Licensees may exclude from the calculation of an individuals work hours only that portion of a break or rest period during which there is a reasonable opportunity and accommodations for restorative sleep (e.g., a nap).
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§ 26.203 General provisions.
individuals who received only one y
waiver during the reporting period, the g
p g p number of individuals who received a total of two waivers during the reporting period).
(2) A summary of corrective actions, y
if any, resulting from the analyses of y
g these data, including fatigue (g)
(e) Reporting. Licensees shall include p
g the following information in a standard g
format in the annual FFD program p
g performance report required under p
§ 26.717:
(1) A summary for each nuclear power y
p plant site of all instances during the p
g previous calendar year when the p
y licensee waived the work hour controls specified in § 26.205(d)(1) through p
g (d)(5)(i) for individuals described in
§ 26.4(a). The summary must include y
only those waivers under which work y
was performed. If it was necessary to p
y waive more than one work hour control during any single extended work period, g
y g
p the summary of instances must include y
each of the work hour controls that were waived during the period. For each g
p category of individuals specified in g
y p
§ 26.4(a), the licensee shall report
( ),
p (i) The number of instances when each applicable work hour control pp specified in § 26.205(d)(1)(i) through p
g (d)(1)(iii), (d)(2)(i) and (d)(2)(ii), and (d)(3)(i) through (d)(3)(v) was waived for g
individuals not working on outage activities;;
(ii) The number of instances when each applicable work hour control pp specified in § 26.205(d)(1)(i) through p
g (d)(1)(iii), (d)(2)(i) and (d)(2)(ii), (d)(3)(i) through (d)(3)(v), and (d)(4) and (d)(5)(i) g was waived for individuals working on outage activities; and g
(iii) A summary that shows the y
distribution of waiver use among the g
individuals within each category of g
y individuals identified in § 26.4(a) (e.g.,
a table that shows the number of
17230 Federal Register / Vol. 73, No. 62 / Monday, March 31, 2008 / Rules and Regulations (1) Records of FFD training and examinations conducted under § 26.29; and (2) Records of audits, audit findings, and corrective actions taken under
§ 26.41.
(c) Licensees and other entities shall ensure the retention and availability of records pertaining to any 5-year denial of authorization under § 26.75(c), (d), or (e)(2) and any permanent denial of authorization under § 26.75(b) and (g) for at least 40 years or until, on application, the NRC determines that the records are no longer needed.
(d) Licensees and other entities shall retain any superseded versions of the written FFD policy and procedures required under §§ 26.27, 26.39, and 26.203(b) for at least 5 years or until completion of all legal proceedings related to an FFD violation that may have occurred under the policy and procedures, whichever is later.
(e) Licensees and other entities shall retain written agreements for the provision of services under this part for the life of the agreement or until completion of all legal proceedings related to an FFD policy violation that involved those services, whichever is later.
(f) Licensees and other entities shall retain records of the background investigations, credit and criminal history checks, and psychological assessments of FFD program personnel, conducted under § 26.31(b)(1)(i), for the length of the individuals employment by or contractual relationship with the licensee or other entity, or until the completion of all related legal proceedings, whichever is later.
(g) If a licensees or other entitys FFD program includes tests for drugs in addition to those specified in this part, as permitted under § 26.31(d)(1), or uses more stringent cutoff levels than those specified in this part, as permitted under § 26.31(d)(3), the licensee or other entity shall retain documentation certifying the scientific and technical suitability of the assays and cutoff levels used, as required under § 26.31(d)(1)(i) and (d)(3)(iii)(C), respectively, for the time the FFD program follows these practices or until the completion of all related legal proceedings, whichever is later.
§ 26.715 Recordkeeping requirements for collection sites, licensee testing facilities, and laboratories certified by the Department of Health and Human Services.
(a) Collection sites providing services to licensees and other entities who are subject to this subpart, licensee testing facilities, and HHS-certified laboratories shall maintain and make available documentation of all aspects of the testing process for at least 2 years or until the completion of all legal proceedings related to a determination of an FFD violation, whichever is later.
This 2-year period may be extended on written notification by the NRC or by any licensee or other entity for whom services are being provided.
(b) Documentation that must be retained includes, but is not limited to, the following:
(1) Personnel files, including training records, for all individuals who have been authorized to have access to specimens, but are no longer under contract to or employed by the collection site, licensee testing facility, or HHS-certified laboratory; (2) Chain-of-custody documents (other than forms recording specimens with negative test results and no FFD violations or anomalies, which may be destroyed after appropriate summary information has been recorded for program administration purposes);
(3) Quality assurance and quality control records; (4) Superseded procedures; (5) All test data (including calibration curves and any calculations used in determining test results);
(6) Test reports; (7) Records pertaining to performance testing; (8) Records pertaining to the investigation of testing errors or unsatisfactory performance discovered in quality control or blind performance testing, in the testing of actual specimens, or through the processing of appeals and MRO reviews, as well as any other errors or matters that could adversely reflect on the integrity of the testing process, investigation findings, and corrective actions taken, where applicable; (9) Performance records on certification inspections; (10) Records of preventative maintenance on licensee testing facility instruments; (11) Records that summarize any test results that the MRO determined to be scientifically insufficient for further action; (12) Either printed or electronic copies of computer-generated data; (13) Records that document the dates, times of entry and exit, escorts, and purposes of entry of authorized visitors, maintenance personnel, and service personnel who have accessed secured areas of licensee testing facilities and HHS-certified laboratories; and (14) Records of the inspection, maintenance, and calibration of EBTs.
§ 26.717 Fitness-for-duty program performance data.
(a) Licensees and other entities shall collect and compile FFD program performance data for each FFD program that is subject to this subpart.
(b) The FFD program performance data must include the following information:
(1) The random testing rate; (2) Drugs for which testing is conducted and cutoff levels, including results of tests using lower cutoff levels, tests for drugs not included in the HHS panel, and any special analyses of dilute specimens permitted under
§ 26.163(a)(2);
(3) Populations tested (i.e.,
individuals in applicant status, permanent licensee employees, C/Vs);
(4) Number of tests administered and results of those tests sorted by population tested (i.e., individuals in applicant status, permanent licensee employees, C/Vs);
(5) Conditions under which the tests were performed, as defined in
§ 26.31(c);
(6) Substances identified; (7) Number of subversion attempts by type; (8) Summary of management actions; and (9) The information required under
§ 26.203(e)(1) and (e)(2).
(c) Licensees and other entities who have a licensee-approved FFD program shall analyze the data at least annually and take appropriate actions to correct any identified program weaknesses.
Records of the data, analyses, and corrective actions taken must be retained for at least 3 years or until the completion of any related legal proceedings, whichever is later.
(d) Any licensee or other entity who terminates an individuals authorization or takes administrative action on the basis of the results of a positive initial drug test for marijuana or cocaine shall also report these test results in the annual summary by processing stage (i.e., initial testing at the licensee testing facility, testing at the HHS-certified laboratory, and MRO determinations).
The report must also include the number of terminations and administrative actions taken against individuals for the reporting period.
(e) Licensees and other entities shall submit the FFD program performance data (for January through December) to the NRC annually, before March 1 of the following year.
(f) Licensees and other entities may submit the FFD program performance data in a consolidated report, as long as the report presents the data separately for each site.
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§ 26.717 Fitness-for-duty program
§ performance data.
(9) The information required under
§ 26.203(e)(1) and (e)(2).
j p
(b) The FFD program performance p
g p
data must include the following information:
(c) Licensees and other entities who
( )( )
( )( )
have a licensee-approved FFD program pp p
g shall analyze the data at least annually y
y and take appropriate actions to correct pp p
any identified program weaknesses.
y p
g Records of the data, analyses, and y
corrective actions taken must be retained for at least 3 years or until the y
completion of any related legal p
y g
proceedings, whichever is later.
p g p (e) Licensees and other entities shall performance submit the FFD program p data (for January through December) to p
g J
y g
the NRC annually, before March 1 of the following year.
g y (f) Licensees and other entities may submit the FFD program performance p
g p
data in a consolidated report, as long as p
g the report presents the data separately p
p for each site.