ML19275H980
| ML19275H980 | |
| Person / Time | |
|---|---|
| Issue date: | 05/09/1980 |
| From: | Morrison W NRC OFFICE OF STANDARDS DEVELOPMENT |
| To: | Eisenhut D, Hanauer S, Mattson R Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML19275H981 | List: |
| References | |
| FOIA-81-61, TASK-OS, TASK-RS-018-1, TASK-RS-18-1 NUDOCS 8006270164 | |
| Download: ML19275H980 (15) | |
Text
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R.3. Minogue R. G. Smith G. A. Arlotto s
'.W. M. Morrison
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MEMORANDUM FOR: D.G.Eisenbut, Director,CdtTNRR (5)
S. D. Hanauer, Director, CHFS, NRR (2)
R. J. Mattson, Director, DST, NRR (2)
N. C.. seiey, Director, DROI, IE (2)
- 3. A W:-$"% Director, DRCI, IE (2)
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R'. J. Budnitz, Director, RES' H. K. Shapar, Director, El.D FRCM:
W. M. Morrison, Assistant Director for General Engineering Standards Division of Engineering Standards Office of Standards Development
SUBJECT:
PROPOSED RULEMAKING - STAFFING AND MAXIMUM WORXING HO 1.
Title:
10 CFR S0.E4 Conditions of Licanses
- 2. 50 Task Leader:
G. F. Guppy
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- 3. SD Task Nu::ber: RS 018-1
- 5. Requested Action: Review, cocnent and make recomendations
- 6. Requested Due Date: Mayl0,1980
- 7.
Background:
Current NRC Regulations require one operator in the control room at all times with an additional operator required for certain operations such as startup of the plant. There are no established craximu::: verking hour regulations. The proposed rule reflects NUREG-0578 recomc:endations for staffing of control races and the IE Circular 80-02 for maximum working hours. The prpposed rule is being forwarded for staff review prior to the public cc:::: lent period.
- M wped hr W. u. mca W. M. Morrison, Assistant Director for General Engineering Standards i
Enclosure:
as Stated.
Division of Engineering Standards cc:
D. S. Skovholt, NRR Office of Standards Cevelopc:ent P. F. Collins, NRR J. J. Holman, NRR DISTRIBUTION CENTaAt FILE 8006270 /(/
J. C. Stone, IE 50 At?HA SD a0 S. H. Hanauer, NRR Y. A. Moore, NRR TAS NO.
RS-018-1 RSSB WR 313
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NRC Form 313A i4 7h NRCM 02040 e............,...,....,..e.
[7590-01]
NUCLEAR REGULATORY CCMMISSION
[10 CFR Part 50]
STAFFING AND MAXIMUM WORKING HOURS AT NUCLEAR POWER PLANTS AGENCY:
Nuclear Regulatory Commissior.
ACTION:
Propo:ed Rule.
SUMMARY
The Nuclear Regulatory Ccmmission is proposing to amend its regulations to (1) reflect the need for increased manning at nuclear power plants and (2) establish working hours limitations at nuclear power plants to prevent fatigue caused by excessive working hours.
DATES:
Comment period expires
- ACDRESSES:
Written comments should be submitted to the Secretary of the Commission, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555, Attention:
Docketing and Service Branch.
FOR FURTHER INFORMATION CONTACT:
Mr. G. F. Guppy, Office of Standards Develcpment, U.S. Nuclear Regulatory Ccmmission, Washington, D.C. 20555, teiepnone 301-443-591I SUPPLEMENTARY INFORMATION:
The Nuclear Regulatory Ccamission has under consideration amendments to its regulations in 10 CFR Part 50, " Domestic Licensing of Production and Utilization Facilities." The purpose of the amendments is to revise ss50.54(k), 50.54(m) and add 550.54(q) to specify
^60 cays af ter publication in the Federal Register.
1
[7590-01]
manning levels for control rooms as a result of recommendations made in investigations of the Three Mile Island accident.
These recommendations are reflected in Tasks I.A.1.1, I.A.1.3, and I.A.I.4 of NUREG-0660(")
"TMI-2 Action Plan" (draft 4).
NRC staff proposals reflect guidance in an NRC letter to all operating licensees and applicants for licenses dated The guidance states that one senior operator (SRO) and one operator (RO) will be in the control room at all times and provides for a minimum number of individuals on shift to ensure that this will be so.
Additionally, the purpose is to establish maximum working hours with the intent of eliminating errors caused by fatigue from excessive working hours.
The Office of Inspection and Enforcement has issued a circular 80-02, " Nuclear Power Plant Staff Work Hours,"(") to all licensees dated February 1, 1980, which contained working hour limitations identical to this proposed rule.
Subsequently, en February 8, 1980 the Commission approved application of these working hour limitations to those facilities wno expect to receive operating licenses in the near future.
These hours are as follows:
Except in an emergency:
a.
No more than 12 consecutive hours in a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period.
b.
, rest period of at least 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> between work periods.
c.
No more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in any seven day period.
d.
No more than 14 consecutive days witnout at least two consecutive days off.
"These cocuments are available in the NRC Public Document Room,1717 St.,
NW., '.lashi ngton, D. C.
20555 for insoection and copying.
2
[7590-01]
Scme of the things considered prior to picking the proposed staff and working hour limitations were:
NUREG 0585** "TMI-2 Lessons Learned Task Force Final Report" concerning a.
control room staffing, b.
An NRC letter to all licensees and applicants entitled, "
- dated concerning control room and shift staffing.
The proposed rule conforms very closely to the requirements contained in this document.
c.
A fatigue study done by Dr. Alan Swain of Sandia Laboratories which he compiled in a working paper entitled, " Effects of Hours on Job on Visual Detection and Decision-Making with Implications for Nuclear Power Plant Personnel."** Or. Swain was unable to establish maximum daily or weekly working hours which would not likely lead to degraded performance.
d.
A review of Federal Regulations for presently established working limitations.
This review established that the Federal Aviation Agency (FAA), the Fes.ral Railway Administration (FRA) and the Federal.sighway Administration (F4A) all had maximum working hours for various occupations under their juiisdiction.
None of these occupations were considered to have similarity in both stress and responsibility when compared to the occupation of nuclear power plant operators, and therefore their established working hour limits were not used as a basis for establishing working hour limits for nuclear power plant operators.
"inese cocuments are available in the NRC Public Document Room,1717 H St.,
NW., Washington, D.C.
20555 for inspection and copying.
3
[7590-01]
e.
A review of various State Regulations concerning working hour limits established that states in general have working hour limits only for minors.
f.
The Office of Inspection and Enforcement Circular 80-02 " Nuclear Power Plant Staff Work Hours" issued February 1, 1980 which contains working hour limits identical to the proposed rule.
Pursuant to the Atomic Energy Act of 1954, as amended, and section 533 of title 5 of th-United States Code, notice is hereby given that adoption of the following amendments to 10 CFR Part 50 is contemplated.
All interested persons who desire to submit written comments or suggestions for consideration in connection with the proposed amendments should send them to the Secretary of the Commission, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555, Attention:
Docketing and Service Branch by Copies of comments received on the proposed rulemaking may be examined in the Ccmmission's Public Document Rcom at 1717 H Street, NW., Washington, D.C.
1.
Paragraph 54.(k) of 10 CFR Part 50 is revised to read as follows:
[(k3--An-eperster-er-senter eperster-iicensed perstant-to-Part-55 of-this chapter shsil-be present st-the-c:ntreis st sil-times-dering-the eperstien Of-the-faciiity-]
(k) Mar. ling of control rooms shall be as follows:
(1) For each facility with fuel in a re:ctor core there shall be a shift sucervisor licensed oursuant to Part 55 as a senior coerator at the facility all times.
The shift suoervisor is a senior coerator designated by management to be in charge of shift crew.
" 50 aays after publication in the FEDERAL REGISTER.
4
[7590-01]
(2)
For each facility with fuel in the reactor core there shall be an coerator licensed oursuant to Part 55 in the control room at all times.
(3) A Senior Ooerator licensed oursuant to Part 55 shall be cresent to directly supervise core alterations.
This person shall not be assioned any other concurrent coerational duties.
(4)
In sincie facilities, one senior coerator and two coerators licensed oursuant to Part 55 of this chacter shall.be cresent in the control room at all times durina the coeration of the facility.
(5)
In multiple facilities with seoarate control rooms one senior ocerator and two coerators licensed oursuant to Part 55 of this chaoter shall be cresent in the control room in each facility at all times durina the coeration of the facility.
(6)
In multiole facilities with a common control room one senior coerator and one coerator shall be cresent in the control room to control each facility at all times durina the coeration of the facility.
An additional coerator licensed oursuant to Part 55 on all facilities controlled from the common control room shall be cresent in the common control room.
If no coerators are licensed oursuant to Part 55 on all facilities controlled ' rom the common control room, then the orovisions of (5) above acoly.
(7) Provisions shall be made for one coerator of the two coerators licensed oursuant to Part 55, to leave the control room to tour the facility for routine matters or to investicate crablem areas.
(8) At all sites there shall be at least one more senior coerator licensed oursuant to Part 55 on each shift than the nurber of facilities in coeration at the site.
5
[7590-01]
1 2.
Paragraph 54(m) of 10 CFR Part 50 is revised to read as follows:
[(m3--A-senior operator-iicensed parscant-to-?stt-55 of-this chapter shafi-be present st-the-facility cr-readify sysiisbie en esil st sii-times during-its eperation-and-shsil-be present st-the-facility-dering-initisi start p and sppresch-to pewer--recovery-frem an enpisnned or-::nsched:: led-shet-down er-significant reduction-in power-snd-ref::eiing-or-ss-etherwise prescribed-in-the-facility-iicense-]
(m) A Shift Technical Advisor trained in accident analysis shall be cresent at the site durino coeration of any facility and readily available (within 10 minutes) to advise the senior coerator in the event a facility exoeriences an off-normal event or accident.
3.
Section 54 of 10 CFR Part 50 is amended by adding a new paragraph (q) to read as follows:
(c) Exceot in an emergency the below working hour limitations acoly to cersonnel who coerate, or maintain, or suoervise oersonnel who coerate or maintain structures, systems, and comoonents imoortant to safety.
If these limitations are to be exceeded the station manager (or ecuivalent organizational cosition) shall deter.aine if the basis exists to imolement longer hours and shall cause accroariate documentation of the reasons for imolementation of longer hours.
(1) A work ceriod of 12 consecutive hours in one day.
(2) A 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> rest oeriod between work ceriods.
(3) 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in any 7-day ceriod.
(4) No more than la consecutive days work without at least two consecutive days (48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />) off.
Incorporates recommendation of NUREG-0578 "TMI-2 Lessons Learned Task Force Status Report and Short Term Recommendations" page A-51 which has been implemented in NRC letter dated October 30, 1979 to operating nuclear power plants.
This document is available in the NRC Public Document Room 1717 H St.,
NW., Washington, D.C.
20555 for inspection and copying.
6
PRELIMINARY VALUE IMPACT ASSESSMENT FOR AMENDMENT TO 10 CFR PART 50 SECTION 54 CONCERNING STAFFING AND MAXIMUM LIMITATIONS FOR WORKING HOURS AT PCWER REACTORS
I.
The Procosed Action A.
Descriotion The proposed action is to initiate proposed rulemaking to revise 10 CFR Part 50, section 54, " Conditions of Licenses" to increase the required number of operators in the control recm and to specify working hour limitations for nuclear power piant personnel.
Action is currently under way to provide additional guidance through a regulatory guide revision and regulation change on additional details reg a rding reccmmendations on staffing and qualifications of these personnel.
Regulatory Guide 1.8, " Personnel Selection and Training" addresses education, experience, and training.
A proposed revision to 10 CFR Part 55, " Operator's Licenses" to be is ued in the near future, will incorporate additional training required prior to receiving an operator license as a result of the TMI-2 accident.
B.
Need for Procosed Action NUREG-0578(I) states en page A-51 that a Shift Technical Advisor (STA) shall be stationed to advise the Shift Supervisor during off-normal occurrences.
NUREG-0585 (2) states on page A-9 that control rooms should be staffed by a Senior Ocerator (SRO) and two Operators (R0's) for each plant in single-unit and multi unit plants with an additional requirement for a Shift Super-visor in multi unit plants.
Multi-unit plants with a common control rocm may reduce their staffing by one RO.
These requirements apply U )NUREG-0578 "TMI-2 Lessons Learned Task Force Status Recort and Short Term Recommendations.
(2)NUREG-0585 "TMI-2 Lessons Learned Task Force Final Report.
These documents are available in the NRC Public Document Roca, 1717 H St.,
NW, Washington, D.C.
20555.
duriag normal operation.
Standard Technical Specifications for plants now contain requirements for staffing above that presently required by 10 CFR Part 50, Section 54, " Conditions of Licenses."
The Standard Technical Specifications require a licensed crew of one SRO and two R0's.
Some nuclear power plants are not currently required to follow Standard Technical Specification requirements.
NUREG-0585 page A-9 makes a recommendation that working hours be limited to two consecutive work periods of more than 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> with a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> rest period between the work periods.
Station Manager (or equivalent organizational position) approval would be required to exceed this with appropriate documentation of the reason.
Current NRC Regulations do not address the subject of working hour limitations.
Although it is recognized that other forces (such as labor unions) have a strong input in this area, a need exists to provide working hour limitations to ensure that off-normal occurrences are not caused because of fatigue due to excessive working hours.
C.
Value/Imcact of the Procesed Action 1.
NRC a.
Value - (1) The proposed action will provide improved guidance to the staff to ensure that staffing of plants is adequate.
(2) The proposed action will provice guidance for staff inspection personnel to ensure that snift opera-tors are not overly tired and unable to efficiently operate the plant.
2
b.
Impact - The NRC staff inspection pr. sonnel will be required to monitor for compliance with an additional regulation in the area of working hours.
2.
Other Government Agencies - Not applicable unless the govern-ment agency is an applicant or licensee, such as TVA.
3.
Industry a.
Value - The proposed action will provide guidance to the industry to eliminate uncertainty as to what the NRC staff considers acceptable in the areas of nuclear power plant control rocm staffing and working hours ar nuclear power plant personnel.
b.
Impact - (1) The proposed action will have the effect of requiring increased hiring and training for some plants that do not meet the proposed staffing requirements.
(2) The industry may have to negotiate with various organizations such as labor unions concerning working hours.
4.
Public a.
Value - The increased staffing requirements in conjunction with limitations on working hours should provide an increased capability to handle off-normal occurrences and therefore offer increased plant safety.
3 t,
3
b.
Impact - The increased staffing requirements may result in rate increase requests by the utilities and therefore may have monetary impact on the public.
5.
Workers (Relative to ALARA)
Not applicable.
D.
Decision on the Procosed Action Increased nuclear power plant staffing requirements and working hour limitations for nuclear power plant personnel should be provided to increase the safety of operation of nuclear power plants.
II.
Technical Acoroach Not applicable to this value/ impact assessment since the proposed action does not address technical alternatives.
III. Procedural Acoroach A.
Procedural Alternatives 1.
Administrative changes at utility level - NUREG 0585 recommends that working hcur limitations be addressed through utility administrative procedures.
The Office of Inspection and Enforcement circular 80-02, " Nuclear Power Plant Staff Work Hours" dated February 1,1980 listed the NRC recommended working hour limitations and the Commission approved this circular's use for Near Term Operating License applicants on February 8, 1980.
Commissioner Bradford further stated in a 4
memorandum dated March 12, 1980 that the recommended working hour limitations of the circular should be incorporated in a rule change to provide for their enforceability.
2.
Regulatory Guide - the use of a Regulatory Guide to address staffing and working hour limitations, while having more force than an administrative procedure, if adopted voluntarily by an applicant or licensee, still does not provide for enforceability as was suggested by Commissioner Bradford.
3.
Regulation - Staffing of nuclear power plants is already addressed by an NRC Regulation, although its requirements are not as strict as the recommendations of NUREG-0585, the Kemeny Report, and the Rogovin Report.
Working hour limitations addressed administratively by the Office of Inspection and Enforcament Circular 80-02 are not made clearly enftrceable without being incorporated into the Regulations.
B.
Selection of Procedural Alternative Since the proposed action concerns in part increased staffing of control rooms and this area is addressed by 10 CFR Part 50, section 54, an amendment to the regulation,has been selected as the proper procedural approach.
IV.
Statutory Consideration A.
NRC Authority This rulemaking would fall under the authority and safety require-ments of the Atomic Energy Act, as amended, and the Energy Reorganization Act, as amended.
5
B.
Need for NEPA Assessment The proposed action is not a major action, as defined by 10 CFR Part 51.5.'a)(10), and does not require an environmental impact statement.
V.
Relationshio to other Existing or Procosed Regulations or Policies No conflicts or overlaps with requirements promulgated by other agencies are forseen.
VI.
Summary and Conclusions An amendment to 10 CFR Part 50 section 54 should be prepared to reflect increased control room staffing requirements and to state limitations on working hours.
6