NRC Generic Letter 1982-12
| ML031080297 | |
| Person / Time | |
|---|---|
| Issue date: | 06/15/1982 |
| From: | Eisenhut D G Office of Nuclear Reactor Regulation |
| To: | |
| References | |
| GL-82-012, NUDOCS 8203160341 | |
| Download: ML031080297 (8) | |
w-' ir.June 15, 1982TO ALL LICENSEES OF OPERATING PLANTS, APPLICANTS FOR ANOPERATING LICENSE, AND HOLDERS OF CONSTRUCTION PERMITSGentlemen:SUBJECT: NUCLEAR POWER PLANT STAFF WORKING HOURS(Generic Letter No. 82-12)On February 8, 1982, we-forwarded to you a copy of a policy statementissued by the Commission entitled "Policy on Factors Causing Fatigueof Operating Personnel at Nuclear Reactors." That policy statementhas now been slightly revised and the revised version is attached tothis letter. The forwarding letter (Generic Letter 82-02) stated thatactions were underway to incorporate the Commission policy on workinghours into Regulatory Guide 1.33 and into NUREG-0737 (Item I.A.1.3).Publication of Regulatory Guide 1.33 is now anticipated in June 1982,following release of ANS 3.2. Revised pages of NUREG-0737 that incor-porate the Commrission policy on working hours are enclosed.Our letter of February 8, 1982 requested that you take action asnecessary to revise the administrative section of your technical speci-fications to assure that your plant administrative procedures followthe revised working hour guidelines, including a provision for docu-mentation of authorized deviations which should be available for NRCreview. You should review your pist actions to assure that they areconsistent with the attached revised policy statement. Note that therevised guidelines are to be incorporated by October 1, 1982.Sincerely,Darrell G. Eisenhut, DirectorDivision of LicensingOffice of Nuclear Reactor RegulationAttachment: -Revision to Item I. ..of NUREG-0737e206160341PDR ADOCK 05000003P PXWUOL*SEE PREVIOUS PAGE FOR CONCURRENCEOFFICE ......... D L. ....... .... ..... ....
- Lp...... .u/................R.........U Verrelli:cw Tt"OVito #c fak GL iias R" X isco DEisejhutSURNAMEk i....................... .... ...... .R..... ... ..... ......... .. ............ ..... ..... t h.... .... ........................6/9/82 6/, V82 6/24/82 6/\8282 6/0 /82DATE 0 ........ ..... .........'.4..............* ...... .- .---- .......... ... ................. ...... .............. ........................ ............IA t j _ _ _ _ _ _ _NRC FORM 318 (10-80) NRCM 0240OFFICIAL RECORD COPYUSGPO: 1981;359wX
.I " ..1, ..-, ITO ALL LICENSEES OF OPERATING PLANTS, APPLICANTS FOR AN`OPERATING LICENSE, AND HOLDERS OF CONSTRUCTION PERMITSGent:SUBJECT: \UCLEAR POWER PLANT STAFF WORKING HOURSOn February 8, '982, we forwarded to you a copy of a policy statementissued by the Coimiss1on entitled "Policy on Factors Causing Fatigueof Operating Perso' el at Nuclear Reactors.' That policy statementhas now been slightty revised and the revised version is attached tothis letter. The forwarding letter (Generic Letter 82-02) stated thatactions were underway to incorporate the Commission policy on workinghours into Regulatory Gu1 e 1.33 and into NUREG-0737 (Item I.A.1.3).Publication of Regulatory G de 1.33 is now anticipated in June 1982,following release of ANS 3.2. Revised pages of NUREG-0737 that incor-porate the Commission policy o working hours are enclosed.It Is requested that you take acti n as necessary to revise theadministrative section of your tech ical specifications to assure thatyour plant administrative procedures Ilow the revised working hourguidelines, Including a provision for ocumentation of authorizeddeviations which should be available fo NRC review. Note that therevised guidelines are to be incorporate by October l, 1982.Attachment:Revision to Item I.A.1.3of NUREG-0737Sincerely,Darrell G. ' enhut, DirectorDivision of Li ensingOffice of Nue ctor Regulation-I I, .-* Y., , , .D FCE DL:ORAB DL:AD/OR DL:AD/SAOFFICE............ ............. ........................FUA D er cw TIppolito TNovak GLainasA E.......... ..... ............... ......... ....DATEk t ........... ............. ................... ........................DL:AD/L DL:DIR........................ ....... .................. .....\ ... ........................RTedesco DEisenhut........ .... I.. .....8 ................................ .....1 ..8 2 ......6.t ........................NRC FORM 318 (10-80) NRCM 0240USOPO: 1981-335-960OFFICIAL RECORD COPYUSGPO: 1951-35961 I.A.1.3 SHIFT MANNINGPages I.A.1.3-1 through I.A.1.3-3 are replaced in their entirety by the following.A bar in the margin indicates changes from the material originally included onthese pages.PositionThis position defines shift manning requirements for normal operation. The letterof July 31, 1980 from D. G. Eisenhut to all power reactor licensees and applicants(copy attached) sets forth the interim criteria for shift staffing (to be effectivepending general criteria that will be the subject of future rulemaking). Overtimerestrictions were also included in the July 31, 1980 letter.Changes to Previous Requirements and GuidanceErrors were discovered in the last column of the table attached to the letter ofJuly 31, 1980. A corrected table is enclosed; a bar in the margin Indicates thecorrection. (See p. I.A.1.3-4.)The overtime requirements have been rewritten to incorporate the provisions of aCommission policy statement on working hours and operator fatigue. IClarificationLicensees of operating plants and applicants for operating licenses shall includein their administrative procedures (required by license conditions) provisionsgoverning required shift staffing and movement of key individuals about the plant.These provisions are required to assure that qualified plant personnel to man theoperational shifts are readily available in the event of an abnormal or emergencysituation.
-.2 -These administrative procedures shall also set forth a policy, the objective ofwhich is to prevent situations where fatigue could reduce the ability of operatingpersonnel to keep the reactor in a safe condition. The controls establishedshould assure that, to the extent practicable, personnel are not assigned toshift duties while in a fatigued condition that could significantly reduce theirmental alertness or their decision making ability. The controls shall apply tothe plant staff who perform safety-related functions (e.g., senior reactoroperators, reactor operators, auxiliary operators, health physicists, and keymaintenance personnel).IE Circular No. 80-02, Nuclear Power Plant Staff Work Hours", dated February 1,1980 (copy attached) discusses the concern of overtime work for members of theplant staff who perform safety-related functions. The guidance contained inIE Circular No. 80-02 was amended by the July 31, 1980 letter. In turn, theovertime guidance of the July 31, 1980 letter was revised in Section I.A.1.3of NURG-0737. The NRC has issued a policy statement (attached) which furtherrevises the overtime guidance as stated in NUREG-0737. This guidance is asfollows:Enough plant operating personnel should be employed to maintain adequate shiftcoverage without routine heavy use of overtime. The objective is to have operatingpersonnel work a normal 8-hour day, 40-hour week while the plant is operating.However, in the event that unforeseen problems require substantial amounts ofovertime to be used, or during extended periods of shutdown for refueling, majormaintenance or major plant modifications, on a temporary basis, the followingguidelines shall be followed:
-3-a. An individual should not be permitted to work more than 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> straight(excluding shift turnover time).b. An individual should not be permitted to work'more than 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> in any24-hour period, nor more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in any 48-hour period, nor morethan 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 (all excluding shift turnover time).c. A break of at least eight hours should be allowed between work periods(including shift turnover time).d. Except during extended shutdown periods, the use of overtime should beconsidered on an individual basis and not for the entire staff on shift.Recognizing that very unusual circumstances may arise requiring deviation fromthe above guidelines, such deviation shall be authorized by the plant manageror his deputy, or higher levels of management. The paramount consideration insuch authorization shall be that significant reductions in the effectiveness ofoperating personnel would be highly unlikely. Authorized deviations' Wttheworking hour guidelines shall be documented and available for NRC review.In addition, procedures are encouraged that would allow licensed operators atthe controls to be periodically relieved and assigned to other duties away fromthe control board during their tours of duty.Operating license applicants shall complete these administrative proceduresbefore fuel loading. Development and implementation of the administrativeprocedures at operating plants will be reviewed by the Office of Inspectionand Enforcement beginning Oct. 1, 1982.
- - 4 --4-See Section III.A.1.2 for minimum staffing and augment capabilities foremergencies.ApplicabilityThis requirement applies to all licensees of operating reactors and applicantsfor operating licenses.Implementation(1) Overtime administrative procedures shall be established for operatingreactors by Oct. 1, 1982 and by fuel loading for applicants for operatinglicense.(2) Staffing requirements shall be completed by July 1, 1982 for operatingreactors and by fuel load for operating license applicants.Type of ReviewA post-implementation review will be performed on operating reactors.Applicants for operating licenses will be reviewed prior to implementation.Documentation RequiredThe documentation required is as noted in the letter of July 31, 1980.Technical Specification Changes RequiredChanges to Technical Specifications will be required for overtime administrativeprocedure and staffing requirements.
p.- 5 --5-ReferencesNUREG-0660IE Circular No. 80-02, "Nuclear Power Plant Staff Work Hours," February 1, 1980Letter from D. G. Eisenhut, NRC, to All Power Reactor Licensees, July 31, 1980Policy on Factors Causing Fatigue of Operating Personnel at Nuclear Reactors,
-r.5W --POLICY ON FACTORS CAUSING FATIGUE OF OPERATINGPERSONNEL AT NUCLEAR REACTORSLicensees of operating plants and applicants for operating licenses shallestablish controls to prevent situations where fatigue could reduce the abilityof operating personnel to keep the reactor in a safe condition. The controlsshould focus on shift staffing and the use of overtime--key job-related factorsthat influence fatigue.The objective of the controls would be to assure that, to the extent practicable,personnel are not assigned to shift duties while in a fatigued condition thatcould significantly reduce their mental alertness or their decision makingcapability. The controls shall apply to the plant staff who perform safety-related functions (e.g., senior reactor operators, reactor operators, healthphysicists, auxiliary operators, and key maintenance personnel).Enough plant operating personnel should be employed to maintain adequate shiftcoverage without routine heavy use of overtime. The objective is to haveoperating personnel work a normal 8-hour day, 40-hour week while the plant isoperating. However, in the event that unforeseen problems require substantialamounts of overtime to be used, or during extended periods of shutdown forrefueling, major maintenance or major plant modifications, on a temporary basis,the following guidelines shall be followed:a. An individual should not be permitted to work more than 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br />straight (excluding shift turnover time).b. An individual should not be permitted to work more than 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br />sin any 24-hour period, nor more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in any 48-hourperiod, nor 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 (allexcluding shift turnover time).c. A break of at least eight hours should be allowed between workperiods (including shift turnover time).d. Except during extended shutdown periods, the use of overtimeshould be considered on an individual basis and not for theentire staff on a shift.Recognizing that very unusual circumstances may arise requiring deviation fromthe above guidelines, such deviation shall be authorized by the plant manageror his deputy, or higher levels of management. The paramount considerationin such authorization shall be that significant reductions in the effectivenessof operating personnel would be highly unlikely.In addition, procedures are encouraged that would allow licensed operators at thecontrols to be periodically relieved and assigned to other duties away from thecontrol board during their tour of duty.