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
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.
1
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 10 CFR Part 26, Subpart I - Managing Fatigue Annual Fatigue Reporting Form for the EIE General Submission Portal Note:
Select Facility Period of Report 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.
Please Select Please Select Today is: Nov 5, 2012 Submission Update - check this box only if this is an update to a previous submission.
Did your facility issue any waivers in the Was this facility in an outage for any part of the Did any single site outage last more than 60 Did any of the first 60 days of an outage occur Did any of the outage days after day 60 occur reporting period? (Yes / No) reporting period? (Yes / No) days in total? (Yes / No) during the reporting period? (Yes / No) during the reporting period? (Yes / No)
Please Select Please Select Please Select Please Select Please Select Summary of Waiver Issuance - 26.203(e)(1)(i-ii)
Number of Waivers Issued Operating or on-site directing of Performing health physics or Performing duties of a fire brigade Performing maintenance or Performing security duties, as Operating Outage Outage Combined Work Hour Controls the operations of systems,as chemistry duties, as described in member, as described in onsite direction of maintenance, described in Total Total Total Total described in 26.4(a)(1) 26.4(a)(2) 26.4(a)(3)
- as described in 26.4(a)(4) 26.4(a)(5) (days 1-60) (after day 60)
Outage Outage Outage Outage Outage Outage Outage Outage Outage Outage (Calculated) (Calculated) (Calculated) (Calculated)
Operating Operating Operating Operating Operating (days 1-60) (after day 60) (days 1-60) (after day 60) (days 1-60) (after day 60) (days 1-60) (after day 60) (days 1-60) (after day 60)
Exceeded 16 work hrs in any 24 hr period Daily Work Hours Exceeded 26 work hrs in any 48 hr period 26.205(d)(1)
Exceeded 72 work hrs in any 7 day period Less than 10 hr break b/t successive work Rest periods (or 8 hr break accommodating Breaks scheduled transition b/t shifts) 26.205(d)(2)
Less than 34 hr break in any 9 day period Average of less than 1 day off per week for 8-hour shifts Average of less than 2 days off per week Minimum for 10-hour shifts Days Off Average of less than 2.5 days off per week Per Shift for 12-hour shifts Cycle 26.205(d)(3) 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 Less than 3 days off per successive 15-day Minimum Days Off period 26.205.(d)(4) for Outage Activities (during first Less than 1 day off per 7-day period for 60 days of outage) maintenance personnel 26.205.(d)(4) 26.205(d)(4) and 26.205(d)(5) Less than 4 days off per successive 15-day period for security personnel 26.205.(d)(5)
Alternate to Minimum 54 hour6.25e-4 days <br />0.015 hours <br />8.928571e-5 weeks <br />2.0547e-5 months <br /> maximum average Days Off 26.205(d)(7)
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.
Distribution of Waivers for Individuals in Each Category - 26.203(e)(1)(iii) Summary of Corrective Action - 26.203(e)(2) (as applicable)
Number of Employees Issued Waivers Analysis of Waiver Assessment Data: (Limit 10,000 characters)
[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]
Operating or on-site Performing health Performing duties of a Performing maintenance directing of Performing security physics or chemistry fire brigade member as or onsite directing of the operations of duties as described in Number of Waivers duties as described in described in maintenance as systems, as 26.4(a)(5) 26.4(a)(2) 26.4(a)(3)
- described in 26.4(a)(4) described in 26.4(a)(1) 1 Analysis of Fatigue Assessment Data: (Limit 10,000 characters) 2 3
4 5
Conclusions:
(Limit 10,000 characters) 6 7
8 Summary and Status of Corrective Actions: (Limit 10,000 characters) 9 10 11 - 20 More than 20 Total Employees General Comments (optional) (Limit 10,000 characters)
Issued Waivers (Calculated)
Most Waivers Provided to a Single Individual
- 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.
Person(s) Responsible for Information Provided Person 1 (required): Person 2 (optional):
First Name Last Name Position Title Company Email Address First Name Last Name Position Title Company Email Address 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: Save to Local PC Print this Report Annual Fatigue Results Form (version 1.4.0 - Nov 5, 2012)
17224 Federal Register / Vol. 73, No. 62 / Monday, March 31, 2008 / Rules and Regulations Subpart IManaging Fatigue and risk factors for common sleep individuals who received only y one disorders, shiftwork strategies for waiver duringg the reporting p g period, p the
§ 26.201 Applicability. obtaining adequate rest, and the number of individuals who received a The requirements in this subpart effective use of fatigue countermeasures; total of two waivers during the reporting apply to the licensees and other entities and period).
identified in § 26.3(a), and, if applicable, (2) Ability to identify symptoms of (2) A summary y of corrective actions, (c) and (d). The requirements in worker fatigue and contributors to if any, y resultingg from the analyses of
§§ 26.203 and 26.211 apply to the decreased alertness in the workplace. these data, including fatigue individuals identified in § 26.4 (a) (d) Recordkeeping. Licensees shall assessments.
through (c). In addition, the retain the following records for at least (f) Audits. Licensees shall audit the requirements in § 26.205 through 3 years or until the completion of all management of worker fatigue as
§ 26.209 apply to the individuals related legal proceedings, whichever is required by § 26.41.
identified in § 26.4(a). later:
(1) Records of work hours for § 26.205 Work hours.
§ 26.203 General provisions. individuals who are subject to the work (a) Individuals subject to work hour (a) Policy. Licensees shall establish a hour controls in § 26.205; controls. Any individual who performs policy for the management of fatigue for (2) Records of shift schedules and duties identified in § 26.4(a)(1) through all individuals who are subject to the shift cycles of individuals who are (a)(5) shall be subject to the licensees FFD program and incorporate subject to the work hour controls in requirements of this section.
it into the written policy required in § 26.205; (b) Calculating work hours. For the
§ 26.27(b). (3) The documentation of waivers that purposes of this section, a licensee shall (b) Procedures. In addition to the is required in § 26.207(a)(4), including calculate the work hours of individuals procedures required in § 26.27(c), the bases for granting the waivers; who are subject to this section as the licensees shall develop, implement, and (4) The documentation of work hour amount of time the individuals perform maintain procedures that reviews that is required in § 26.205(e)(3)
(1) Describe the process to be duties for the licensee. Except as and (e)(4); and followed when any individual (5) The documentation of fatigue permitted by paragraphs (b)(1) through identified in § 26.4(a) through (c) makes assessments that is required in (b)(5) of this section, the calculated a self-declaration that he or she is not § 26.211(g).
(g) work hours must include all time fit to safely and competently perform (e) Reporting.
p g Licensees shall include performing duties for the licensee, his or her duties for any part of a the followingg information in a standard including all within-shift break times working tour as a result of fatigue. The format in the annual FFD programp g and rest periods during which there are procedure must performance p report required under no reasonable opportunities or (i) Describe the individuals and § 26.717: accommodations appropriate for licensees rights and responsibilities (1) A summary y for each nuclear power p restorative sleep.
related to self-declaration; plant p site of all instances duringg the (1) Shift turnover. Licensees may (ii) Describe requirements for previous p calendar year y when the exclude shift turnover from the establishing controls and conditions licensee waived the work hour controls calculation of an individuals work under which an individual may be specified p in § 26.205(d)(1) throughg hours. Shift turnover includes only permitted or required to perform work (d)(5)(i) for individuals described in those activities that are necessary to after that individual declares that he or § 26.4(a). The summary y must include safely transfer information and she is not fit due to fatigue; and only y those waivers under which work responsibilities between two or more (iii) Describe the process to be was performed.
p If it was necessaryy to individuals between shifts. Shift followed if the individual disagrees waive more than one work hour control turnover activities may include, but are with the results of a fatigue assessment duringg any y single g extended work period, p not limited to, discussions of the status that is required under § 26.211(a)(2); the summary y of instances must include of plant equipment, and the status of (2) Describe the process for each of the work hour controls that were ongoing activities, such as extended implementing the controls required waived duringg the period.
p For each tests of safety systems and components.
under § 26.205 for the individuals who category g y of individuals specified p in Licensees may not exclude work hours are performing the duties listed in § 26.4(a),
( ), the licensee shall report p worked during turnovers between
§ 26.4(a); (i) The number of instances when individuals within a shift period due to (3) Describe the process to be each applicable pp work hour control rotations or relief within a shift.
followed in conducting fatigue specified p in § 26.205(d)(1)(i) throughg Activities that licensees may not assessments under § 26.211; and (d)(1)(iii), (d)(2)(i) and (d)(2)(ii), and exclude from work hours calculations (4) Describe the disciplinary actions (d)(3)(i) through g (d)(3)(v) was waived for also include, but are not limited to, shift that the licensee may impose on an individuals not working on outage holdovers to cover for late arrivals of individual following a fatigue activities;; incoming shift members; early arrivals assessment, and the conditions and (ii) The number of instances when of individuals for meetings, training, or considerations for taking those each applicable pp work hour control pre-shift briefings for special evolutions; disciplinary actions. specified p in § 26.205(d)(1)(i) throughg and holdovers for interviews needed for (c) Training and examinations. (d)(1)(iii), (d)(2)(i) and (d)(2)(ii), (d)(3)(i) event investigations.
Licensees shall add the following KAs through g (d)(3)(v), and (d)(4) and (d)(5)(i) (2) Within-shift break and rest to the content of the training that is was waived for individuals working on periods. Licensees may exclude from required in § 26.29(a) and the outageg activities;; and the calculation of an individuals work pwalker on PROD1PC71 with RULES comprehensive examination required in (iii) A summary y that shows the hours only that portion of a break or rest
§ 26.29(b): distribution of waiver use amongg the period during which there is a (1) Knowledge of the contributors to individuals within each category g y of reasonable opportunity and worker fatigue, circadian variations in individuals identified in § 26.4(a) (e.g., accommodations for restorative sleep alertness and performance, indications a table that shows the number of (e.g., a nap).
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17230 Federal Register / Vol. 73, No. 62 / Monday, March 31, 2008 / Rules and Regulations (1) Records of FFD training and documentation of all aspects of the § 26.717 Fitness-for-duty program examinations conducted under § 26.29; testing process for at least 2 years or performance data.
and until the completion of all legal (a) Licensees and other entities shall (2) Records of audits, audit findings, proceedings related to a determination collect and compile FFD program and corrective actions taken under of an FFD violation, whichever is later. performance data for each FFD program
§ 26.41. This 2-year period may be extended on that is subject j to this subpart.
p (c) Licensees and other entities shall written notification by the NRC or by (b) The FFD p program g p performance ensure the retention and availability of any licensee or other entity for whom data must include the following records pertaining to any 5-year denial services are being provided. information:
of authorization under § 26.75(c), (d), or (b) Documentation that must be (1) The random testing rate; (e)(2) and any permanent denial of retained includes, but is not limited to, (2) Drugs for which testing is authorization under § 26.75(b) and (g) the following: conducted and cutoff levels, including for at least 40 years or until, on (1) Personnel files, including training results of tests using lower cutoff levels, application, the NRC determines that records, for all individuals who have tests for drugs not included in the HHS the records are no longer needed. been authorized to have access to panel, and any special analyses of dilute (d) Licensees and other entities shall specimens, but are no longer under specimens permitted under retain any superseded versions of the contract to or employed by the § 26.163(a)(2);
written FFD policy and procedures (3) Populations tested (i.e.,
collection site, licensee testing facility, required under §§ 26.27, 26.39, and individuals in applicant status, or HHS-certified laboratory; 26.203(b) for at least 5 years or until permanent licensee employees, C/Vs);
(2) Chain-of-custody documents (4) Number of tests administered and completion of all legal proceedings (other than forms recording specimens related to an FFD violation that may results of those tests sorted by with negative test results and no FFD population tested (i.e., individuals in have occurred under the policy and violations or anomalies, which may be procedures, whichever is later. applicant status, permanent licensee destroyed after appropriate summary employees, C/Vs);
(e) Licensees and other entities shall information has been recorded for retain written agreements for the (5) Conditions under which the tests program administration purposes); were performed, as defined in provision of services under this part for (3) Quality assurance and quality § 26.31(c);
the life of the agreement or until control records; (6) Substances identified; completion of all legal proceedings related to an FFD policy violation that (4) Superseded procedures; (7) Number of subversion attempts by involved those services, whichever is (5) All test data (including calibration type; later. curves and any calculations used in (8) Summary of management actions; (f) Licensees and other entities shall determining test results); and retain records of the background (6) Test reports; (9) The information required under investigations, credit and criminal (7) Records pertaining to performance § 26.203(e)(1)
( )( ) and (e)(2).
( )( )
history checks, and psychological testing; (c) Licensees and other entities who assessments of FFD program personnel, (8) Records pertaining to the have a licensee-approved pp FFD pprogram g
conducted under § 26.31(b)(1)(i), for the investigation of testing errors or shall analyzey the data at least annually y length of the individuals employment unsatisfactory performance discovered and take appropriate pp p actions to correct by or contractual relationship with the in quality control or blind performance anyy identified p program g weaknesses.
licensee or other entity, or until the testing, in the testing of actual Records of the data, analyses, y and completion of all related legal specimens, or through the processing of corrective actions taken must be proceedings, whichever is later. appeals and MRO reviews, as well as retained for at least 3 y years or until the (g) If a licensees or other entitys FFD any other errors or matters that could completion p of anyy related legal g
program includes tests for drugs in adversely reflect on the integrity of the proceedings, whichever is later.
addition to those specified in this part, testing process, investigation findings, (d) Any licensee or other entity who as permitted under § 26.31(d)(1), or uses and corrective actions taken, where terminates an individuals authorization more stringent cutoff levels than those applicable; or takes administrative action on the specified in this part, as permitted basis of the results of a positive initial (9) Performance records on under § 26.31(d)(3), the licensee or other drug test for marijuana or cocaine shall certification inspections; entity shall retain documentation also report these test results in the (10) Records of preventative annual summary by processing stage certifying the scientific and technical maintenance on licensee testing facility suitability of the assays and cutoff levels (i.e., initial testing at the licensee testing instruments; facility, testing at the HHS-certified used, as required under § 26.31(d)(1)(i) (11) Records that summarize any test and (d)(3)(iii)(C), respectively, for the laboratory, and MRO determinations).
results that the MRO determined to be The report must also include the time the FFD program follows these scientifically insufficient for further practices or until the completion of all number of terminations and action; administrative actions taken against related legal proceedings, whichever is (12) Either printed or electronic later. individuals for the reporting p gpperiod.
copies of computer-generated data; (e) Licensees and other entities shall
§ 26.715 Recordkeeping requirements for (13) Records that document the dates, submit the FFD p program g performance p
collection sites, licensee testing facilities, times of entry and exit, escorts, and data (for JJanuary y throughg December) to and laboratories certified by the Department purposes of entry of authorized visitors, the NRC annually, before March 1 of the of Health and Human Services. maintenance personnel, and service following gyyear.
pwalker on PROD1PC71 with RULES (a) Collection sites providing services personnel who have accessed secured (f) Licensees and other entities may y to licensees and other entities who are areas of licensee testing facilities and submit the FFD p program g p performance subject to this subpart, licensee testing HHS-certified laboratories; and data in a consolidated report, p as longg as facilities, and HHS-certified laboratories (14) Records of the inspection, the report p p presents the data separately shall maintain and make available maintenance, and calibration of EBTs. for each site.
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