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Markup of NEI 06-11 Revision 2 with NRC Comments (Managing Personnel Fatigue at Nuclear Power Reactor Sites) for Discussion at Public Meeting on 2017-June-15
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NEI 06-11 [Revision 2]

Managing Personnel Fatigue at Nuclear Power

Reactor Sites April XXXXXX 2014201 7

Nuclear Energy Institute, 1776 I Street N. W., Suite 400, Washington D.C. (202.739.8000)

NEI 06-11 [Revision 2]

Nuclear Energy Institute Managing Personnel Fatigue at Nuclear Power Reactor Sites April XXXXXX 20142017

ACKNOWLEDGEMENTS This document, Managing Personnel Fatigue at Power Reactor Sites, NEI 06-11, was developed by members of the NEI Work Hours Task Force. These industry professionals, experts on access authorization programs, drawing upon practical lessons learned during the application of the previous requirements, provided valuable insights to update the program. The changes provide a more efficient and effective program. Additionally, NEI also wishes to acknowledge the extensive review and comment by those industry representatives who shaped this current revision of this document:

Greg Halnon First Energy Lee Marabella PSE&G Frank Mascitelli Exelon Eddie Humphries Duke Jayne Pearson Wolf Creek Tom Miller First Energy Elizabeth Murtha Areva Jack Heyer IBEW Jim Wheeler Dominion Billie Rooks Southern Nuclear Nick Pappas NEI NOTICE Neither NEI, nor any of its employees, members, supporting organizations, contractors, or consultants make any warranty, expressed or implied, or assume any legal responsibility for the accuracy or completeness of, or assume any liability for damages resulting from any use of, any information apparatus, methods, or process disclosed in this report or that such may not infringe privately owned rights.

NEI 06-11, Revision 2 April XXXXXX 20142017 iEXECUTIVE

SUMMARY

This document provides guidance for managing fatigue in accordance with 10 CFR 26, Subpart I, Managing Personnel Fatigue. The goals of this guide are to provide the tools needed to meet regulatory requirements while:

Maintaining reasonable assurance of industrial and nuclear safety. Recognizing that a wide variety of work situations exist across the industry. Supporting management flexibility and decision making when unplanned work is required. Providing the records needed to allow the required performance evaluations to be performed efficiently. Clarifying the rights and responsibilities of licensees and workers.

NEI 06-11, Revision 2 April XXXXXX 20142017 iii TABLE OF CONTENTS EXECUTIVE

SUMMARY

....................................................................................................... i 1INTRODUCTION AND BACKGROUND ........................................................................

11.1INTRODUCTION

AND B ACKGROUND .............................................................................

11.2BACKGROUND

.............................................................................................................. 11.3OVERVIEW OF FATIGUE MANAGEMENT ...................................................................... 2TABLE 1: OTHER P ART 26 SECTIONS APPLICABLE TO FATIGUE MANAGEMENT ................ 32SCOPE (26.201) ......................................................................................................... 52.1G ENERAL APPLICATION .............................................................................................. 52.2PERSONNEL SUBJECT TO FATIGUE MANAGEMENT ..................................................... 52.3W ORK HOUR CONTROLS ............................................................................................. 5TABLE 2A: SUBPART I REQUIREMENTS FOR DIFFERENT CATEGORIES OF INDIVIDUALS **6TABLE 2B: INDIVIDUALS SUBJECT TO W ORK H OUR CONTROLS (26.205(A)) ..................... 83DEFINITIONS .............................................................................................................. 94POLICY AND PROCEDURES (26.203) ............................................................ 1515144.1P OLICY ............................................................................................................. 1515144.2PROCEDURES ...................................................................................................... 1515145MANAGING FATIGUE (26.203) ....................................................................... 1818175.1INDIVIDUAL SUBJECT TO FATIGUE MANAGEMENT ........................................... 1818175.2REQUIREMENTS ................................................................................................. 1818176WORK HOUR CONTROLS (26.205) ................................................................. 1919186.1INDIVIDUALS SUBJECT TO WORK H OUR CONTROLS ......................................... 1919186.2W ORK HOUR SCHEDULING REQUIREMENTS AND PRINCIPLES (26.205 (C)) ..... 2222206.3W ORK HOUR CONTROLS ................................................................................... 2323216.3.1Applying Work Hour (Ceiling) Limits .............................................. 2323216.3.2Applying Break Requirements .......................................................... 2323216.4METHODS OF WORK HOUR CONTROLS............................................................. 2424226.4.1Minimum Days Off (MDO) ................................................................ 2424226.4.2Maximum Average Work Hours (MAWH) aka On Line Averaging Method ................................................................................................ 2626246.5D EVIATIONS AND COMPLIANCE ......................................................................... 2626247COUNTING WORK HOURS AND BREAK TIME (26.205) .................................. 272725Commented [A1]: TOC should be updated when editing is complete.

NEI 06-11, Revision 2 April XXXXXX 20142016 iv 7.1P ROCESS FOR EVALUATING A SCHEDULE .......................................................... 2727257.2ACCOUNTING OF W ORK H OURS ........................................................................ 2828267.3DAYS O FF ............................................................................................................... 3230TABLE 7: W HAT TO INCLUDE/EXCLUDE W HEN CALCULATING W ORK H OURS ....... 3430328APPLICATION OF MINUMUM DAYS OFF (MDO) AND/OR MAXIMUM AVERAGE (MAWH) WORK HOURS ALTERNATIVE (26.205 (D)(3),(D)(7)) ........................ 3630348.1G ENERAL INFORMATION ................................................................................... 3630348.2MINIMUM DAYS O FF (MDO) METHOD ............................................................. 3730358.2.1Unexpected Outages ........................................................................... 4130398.3MAXIMUM AVERAGE W ORK HOURS (MAWH) ................................................ 4130398.4OUTAGE SPECIFIC GUIDANCE - W ORK H OUR CALCULATIONS ........................ 4330419EXAMPLES OF APPLYING ALL WORK HOUR CONTROLS (26.205) ............... 4530439.1G ENERAL W ORK HOUR REQUIREMENTS .......................................................... 453043TABLE 9A: W ORK HOUR CONTROLS - NORMAL OPERATIONS ................................ 463044TABLE 9B: W ORK H OUR CONTROLS - OUTAGES ..................................................... 483046TABLE 9C: APPLYING E ACH C ONTROL - WORK H OUR LIMITS AND R EST B REAK REQUIREMENTS ................................................................................................. 503048TABLE 9D: APPLYING E ACH C ONTROL - MDO AND MAWH REQUIREMENTS ....... 52305010TRANSITIONS .................................................................................................. 56305410.1T YPES OF TRANSITIONS ..................................................................................... 563054TABLE 10: TRANSITIONS OUT OF AN OUTAGE ........................................................... 59305711WAIVERS (26.207) ......................................................................................... 603058

11.1INTRODUCTION

.................................................................................................. 60305811.2APPLICABILITY .................................................................................................. 60305811.3WAIVER P ROCESS .............................................................................................. 60305811.4SUPERVISORY ASSESSMENT FOR WAIVER OF REGULATORY W ORK HOURS C ONTROLS ......................................................................................................... 62306011.5SEQUESTRATION ................................................................................................ 633061TABLE 11A: W AIVER PROCESS .................................................................................. 653063TABLE 11B: W AIVERS AND EXCEPTIONS TO W ORK H OUR C ONTROLS .................... 67306512SELF DECLARATIONS (26.209) ...................................................................... 69306712.1APPLICABILITY AND GENERAL PROVISION ....................................................... 693067 NEI 06-11, Revision 2 April XXXXXX 20142017 v12.2S ELF-DECLARATIONS DURING EXTENDED WORK HOURS UNDER WAIVER..... 693067TABLE 12: S ELF-DECLARATION PROCESS ................................................................. 70306813FATIGUE ASSESSMENTS (26.211) ................................................................. 713069

13.1INTRODUCTION

.................................................................................................. 71306913.2CONDITIONS REQUIRING FATIGUE ASSESSMENT .............................................. 71306913.3FATIGUE ASSESSMENT ATTRIBUTES .................................................................. 73307113.4R EQUIRED INFORMATION .................................................................................. 74307213.5P ROCESS FOR CONDUCTING FATIGUE ASSESSMENT ......................................... 743072TABLE 13A: FATIGUE ASSESSMENT P ROCESS ........................................................... 763074TABLE 13B: "SUPERVISORY ASSESSMENT OF FITNESS" FOR WAIVERS VS. "FATIGUE ASSESSMENT" .................................................................................................... 78307614TRAINING AND EXAMINATIONS ..................................................................... 79307715RECORDS ....................................................................................................... 803078TABLE 15: DOCUMENTS , REPORTS , AND R EVIEWS REQUIRED UNDER SUBPART I .... 81307916REVIEWS ........................................................................................................ 84308216.1ANNUAL W ORK H OUR C ONTROL EFFECTIVENESS REVIEW ............................. 843082TABLE 16: W ORK H OUR CONTROL EFFECTIVENESS REVIEW P ROCESS .................. 86308417REPORTING .................................................................................................... 87308517.1ANNUAL REPORTING REQUIREMENTS ............................................................... 87308517.2ANNUAL

SUMMARY

OF WAIVERS ...................................................................... 87308517.3ANNUAL

SUMMARY

OF FATIGUE ASSESSMENTS ................................................ 88308617.4I NCIDENT REPORTING REQUIREMENTS ............................................................. 88308618AUDITS ............................................................................................................ 90308818.1C ONDUCT OF AUDITS ......................................................................................... 90308818.2AUDIT RESULTS ................................................................................................. 90308819PERSONNEL ACTIONS .................................................................................... 91308920EXAMPLES ...................................................................................................... 92309021REFERENCES AND RESOURCES .................................................................. 1013099LIST OF TABLES ..................................................................................................... 10230100

NEI 06-11, Revision 2 April XXXXXX 20142016 1 MANAGING PERSONNEL FATIGUE AT NUCLEAR POWER REACTOR SITES 1 INTRODUCTION AND BACKGROUND

1.1 INTRODUCTION

AND B ACKGROUND This guide provides an approach to meeting 10 CFR 26, Subpart I requirements related to managing personnel fatigue at power reactor sites. The management of fatigue is integrated into the industry's fitness-for-duty program and is addressed in NEI 06-11, Managing Personnel Fatigue at Nuclear Power Reactor Sites, NEI 03-01, Nuclear Power Plant Access Authorization Program, and NEI 03-04, Guideline for Plant Access Training. These documents should be used by the licensee s to develop policies, procedures and programs specific to their utility. Training, security and human resource policies as well as labor management and relations practices need to be considered as well in the development of the policies, procedures and programs. This document is presented in a format that will be closely aligned in sequence to 10 CFR 26. Tables are provided in each section for ease of reference to the applicable section in 10 CFR 26. These are for general information, and the actual rule should be referenced for explicit details. This guide also addresses the training and the comprehensive examination that is required by Part 26 for the following new knowledge and abilities (KAs):

Knowledge of the contributors to worker fatigue, circadian variations in alertness andperformance, indications and risk factors for common sleep disorders, strategies that shiftworkers can use for to obtain ing adequate rest, and the effective use of fatigu ecountermeasures.Ability to identify symptoms of worker fatigue and contributors to decreased alertness inthe workplace.The training for other KAs associated with fitness-for-duty (FFD) is addressed in NEI 03-01 and NEI 03-04.

1.2 B ACKGROUND An individual's ability to safely and competently perform his or her duties is not solely based on the individual's hours worked or whether the individual has had adequate rest. Fatigue can be caused by numerous factors including long hours of work, inadequate rest between work periods, sleep disorders, sedentary lifestyles, work problems or dissatisfaction, home finances and relationships, inadequate nutrition, emotional stress, physical stress, prescription drugs, and mental or physical illness. Fatigue may lead to decreased alertness. When an individual is alert, he or she may be more focused and better able to pay attention. Fatigue and decreased alertness can substantively degrade an individual's ability to safely and competently perform his or her duties. NRC edit NRC edit use for obtaining adequate rest, and the effective use of fatigue NEI 06-11, Revision 2 April XXXXXX 20142016 2 Fatigue can be defined as the degradation in an individual's cognitive and motor functioning resulting from inadequate rest. When considering fatigue, the effects of acute fatigue (short-term) and cumulative fatigue (long-term) and an individual's susceptibility to circadian variations should be considered. Fatigue may not be readily observable by a casual observer. Consistent with a station's Behavioral Observation program, individuals should be observed for signs of fatigue which can include, but are not limited to: difficulty staying on task, irritable behavior, disorientation, becoming less communicative, forgetfulness, and tardiness. Fatigue management is vital to ensure that individuals are rested and capable of performing his/her daily tasks without error. An alert individual will be able to remain focused and engaged in their duties.

1.3 OVERVIEW OF FATIGUE MANAGEMENT Fatigue management is part of the licensee's overall fitness-for-duty (FFD) program. In 1982 the Nuclear Regulatory Commission issued Generic Letter 82-12, Nuclear Power Plant Staff Working Hours, providing guidelines for managing the hours worked for individuals performing safety related work. The current rule was driven, in part, by the variation in approaches used across the industry to meet these guidelines. To meet the requirements in Subpart I, a detailed process, as described in this guide, is needed for consistent application of fatigue management principles across the industry. As an integral part of the fitness-for-duty program, sound fatigue management for individuals should be viewed as a way of doing business as opposed to requirements imposed by the NRC.

NEI 06-11, Revision 2 April XXXXXX 20142016 3 TABLE 1: OTHER PART 26 SECTIONS APPLICABLE TO FATIGUE MANAGEMENT

[See rule for details - table provides only general summary of rule] Part 26 Section Notes on Connection to Subpart I 26.1 Purpose States purpose of Part 26 26.3 Scope - entities Referenced explicitly in several sections of Subpart I; provides definitions of entities subject to Subpart I requirements 26.4 Applicability - individuals Referenced explicitly in several sections of Subpart I; provides definitions of individuals subject to specific Subpart I requirements 26.5 Definitions Provides definitions for terms used in Subpart I 26.9 Specific exemptions States that the commission may allow exemptions 26.21 FFD program States general licensee duty to establish, implement, and maintain FFD program 26.23 Performance objectives Includes performance objectives related to managing the effects of fatigue and degraded alertness: 26.23(b) and (e) 26.27 Written policy and procedures Referenced explicitly in Section 26.203(a) and (b); policy and procedures required under Subpart I are to be included as part of those specified in 26.27 26.29 Training Referenced explicitly in Section 26.203(c); training and comprehensive examination required under Subpart I are to be included as part of those specified in 26.29 26.33 Behavioral observation Impairment from fatigue is included as behavior to be detected 26.35 Employee assistance program Provides for employee assistance program, which would include individuals subject to Subpart I 26.37 Protection of information Provides protection of information, including information gathered under Subpart I 26.39 Review process for FFD policy violations Provides process for policy violation review, including those under Subpart I 26.41 Audits and corrective action Referenced explicitly in Section 26.203(f); licensees shall audit the management of worker fatigue as required by 26.41 26.77 Management actions regarding possible impairment Specifically addresses observed behavior or physical condition resulting from fatigue 26.189 Determination of fitness Provides process for determining fitness, including possible impairment from fatigue; requires that determination be performed by a physician and/or MRO with the necessary clinical expertise

NEI 06-11, Revision 2 April XXXXXX 20142016 4 The regulatory approach to managing fatigue relies on two elements: limiting work periods (days and hours) and ensuring adequate time is allotted for breaks and days off. There are two protocols for managing cumulative fatigue: MDO (minimum days off) and MAWH (maximum average work hours). The work hours o schedules for f covered individuals schedules shall be consistent with the objective of preventing impairment from fatigue due to the duration, frequency or sequencing of successive work periods. This requirement is performance based and applies to the schedule of actual hours worked.

Scheduling plays a vital role in fatigue management, as mentioned earlier and in further detail in Sections 6 and 7. It is the responsibility of each individual to report to work in condition to perform his/her duties safely and effectively and to maintain that condition while at work. Management and covered individuals should be equallyshare responsibilityle for properly managing work hours prior to the work being conducted. The NRC holds the licensee is responsible for scheduling workers and ensuring compliance with work hour regulations.

Commented [A2R1]: The original language was hard to follow: "The work hours of covered individuals schedules shall be consistent-." So I support the edits from a grammatical standpoint.

The rule language is "Licensees shall schedule the work hours of individuals who are subject to this section consistent with the objective of preventing impairment from fatigue-." The rule requires the scheduling to be consistent, and the guidance language would require the schedule to be consistent. Is there a difference? NRC edit NRC edit NEI 06-11, Revision 2 April XXXXXX 20142016 5 2 SCOPE (26.201) 2.1 GENERAL APPLICATION This guide applies to licensees who are authorized to operate a nuclear power reactor under 10CFR 50.57 and holders of a combined license under 10 CFR 52 after the commission has made the finding under 10 CFR 52.103(g). This guide also applies to new plant construction no later than upon receipt of special nuclear material in the form of fuel assemblies. This guide does not apply to decommissioned plants not authorized to operate.

2.2 PERSONNEL SUBJECT TO FATIGUE MANAGEMENT All persons who are granted unescorted access to nuclear power reactor protected areas. All persons who are required to physically report to the Technical Support Center or Emergency Operations Facility, in accordance with the site Emergency Plan and procedures (whether they have unescorted access or not). See Tables 1 2A and 2 B for additional relevant information.

2.3 W ORK HOUR CONTROLS 10 CFR 26.205 Work Hours applies to covered individuals (a subset of the individuals to whom the Fatigue Management Program applies) who are granted unescorted access to nuclear power reactor protected areas. Any individual who performs duties within any of the following job categories is a covered individual subject to work hour controls: Operating or on-site directing of the operation of systems and components that a risk-informed evaluation process has shown to be significant to public health and safety. Performing maintenance , or on-site directing of the maintenance, or performing quality inspections during and following maintenance on systems, structures, and components (SSCs) that a risk-informed evaluation process has shown to be significant to public health and safety. Performing health physics or chemistry duties required as a member of the on-site emergency response organization minimum shift complement. Performing the duties of a fire brigade member who is responsible for understanding the effects of fire and fire suppressants on safe shutdown capability. The person specifically designated for understanding the effects of fire and fire suppressants on safe shutdown capability is considered the person responsible for understanding the effects of fire and fire suppressants on safe shutdown capability. The remaining fire brigade members are not considered as the person(s) responsible for understanding the effects of fire and fire suppressants on safe shutdown capability. Performing security duties as an armed security force officer, alarm station operator, response team leader or watchman, hereinafter referred to as security personnel.

NEI 06-11, Revision 2 April XXXXXX 20142016 6 TABLE 2A: SUBPART I REQUIREMENTS FOR DIFFERENT CATEGORIES OF INDIVIDUALS ** [See rule for details - table provides only general summary of the rule]

Sub- section Category of Individual Subpart I CoverageNote 26.4(a) All persons granted unescorted access to nuclear power reactor protected areas (including contractors/vendors) by the licensees in Section 26.3(a) and, as applicable, (c), and who perform the following duties:

(1) Operating or on site directing the operation of systems and components that a risk-informed evaluation process has shown to be significant to public health and safety (2) Performing health physics or chemistry duties as part of on-site emergency response organization minimum shift complement (3) Performing duties of fire brigade member responsible for understanding effects of fire and fire suppressants on safe shutdown capability (4) Performing maintenance or on-site directing of the maintenance or performing quality inspections during and following maintenance on systems, structures and components (SSCs) that a risk-informed evaluation process has shown to be significant to public health and safety.

(5) Performing security duties as an armed security force officer, alarm station operator, response team leader, or watchperson (security personnel) 26.203 - General provisions 26.205 - Work hours 26.207 - Waivers and exceptions 26.209 - Self- declarations 26.211 - Fatigue assessments This is the full fatigue management program, including work hour controls, waivers and exceptions, and self-declaration procedures when working under a waiver 26.4(b) Persons granted unescorted access to nuclear power reactor protected areas by the licensees in Section 26.3(a) and, as applicable, (c) and who do not perform the duties described in 26.4(a) 26.203 - General provisions 26.211 - Fatigue assessments Does not include work hour controls (26.205-209), but does include requirements for self-declaration procedures applicable to all individuals under Subpart I NEI 06-11, Revision 2 April XXXXXX 20142016 7 26.4(c) Persons who are required by a licensee in Section 26.3(a) and, as applicable, (c) to physically report to the licensee's Technical Support Center or EmergencyOperations Facility by licensee emergency plans and procedures 26.203 - General provisions 26.211 - Fatigue assessments Does not include work hour controls (26.205-209), but does include requirements for self-declaration procedures applicable to all individuals under Subpart I

- NOTE: These requirements apply only to operational nuclear power plants

NEI 06-11, Revision 2 April XXXXXX 20142016 8 TABLE 2B: INDIVIDUALS SUBJECT TO W ORK H OUR CONTROLS (26.205(A)) [See rule for details - table provides only a general summary of the rule]

Sub- section Individuals*

Duties Note 26.4(a)(1) Operators All persons with unescorted access operating or on site directing the operation of systems and components that a risk- informed evaluation process has shown to be significant to public health and safety 26.4(a)(2) Health physics or chemistry staff All persons with unescorted access performing health physics or chemistry duties required as a member of on-site emergency response organization minimum shift complement Not necessarily all health physics or chemistry staff-only those who are performing duties of on-site emergency minimum shift complement 26.4(a)(3) Fire brigade members All persons with unescorted access performing duties of fire brigade member responsible for understanding effects of fire and fire suppressants on safe shutdown capability Not necessarily all fire brigade members - only those specifically responsible for understanding the effects of fire and fire suppressants on safe shutdown capability 26.4(a)(4) Maintenance All persons with unescorted access maintaining or on site directing or performing quality inspections of the maintenance of SSCs that a risk-informed evaluation process has shown to be significant to public health and safety See asterisk note below 26.4(a)(5) Security Personnel All persons with unescorted access performing security duties as an armed security force officer, alarm station operator, response team leader, or watchperson Does not include security staff solely performing administrative duties

NOTE: Contractors, if performing the listed duties, are also covered, including maintenance contractors. Commented [A3]: This should be a lower case "a" NRC edit NEI 06-11, Revision 2 April XXXXXX 20142016 9 3 DEFINITIONS Terms Relevant to Fatigue Management Acute Fatigue means fatigue from causes (e.g., restricted sleep, sustained wakefulness, task demands) occurring within the past 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Alertness means the ability to remain awake and sustain attention. Averaging Period means the one- to six-week period over which an individual's per week average work hours are to be calculated; this per week average shall not exceed 54 hours6.25e-4 days 0.015 hours 8.928571e-5 weeks 2.0547e-5 months . The averaging period is set by the licensee and may range from one week to six weeks, with a specified beginning and ending time of day and day of week. The averaging period advances by seven consecutive calendar days at the finish of every averaging period. Break is the interval of time that falls between successive work periods, during which the individual does not perform any duties for the licensee other than shift turnover. Break Requirements are divided into the following: Minimum Work Period Break Requirement: A 10-hour break between the previoussuccessive work period s, or an 8-hour break between the previoussuccessive work period s when a break of less than 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months was necessary to accommodate a crew's scheduled transition between from a unit or security system outage or increased threat condition to operationswork schedules or shifts. Minimum 9-Day Break Requirement: A 34-hour break in the preceding 216-hour (9-day) period. Calculated Work Hours - see Work Hours Calculation Period means the time interval specified in a work hour control requirement used to calculate whether a particular work hour control is met. Call-in means coming to the site to perform unscheduled work. Ceiling Limits

- see Work Hour Limits Circadian variation in alertness and performance means the increases and decreases in alertness and cognitive/motor functioning caused by human physiological processes (e.g., body temperature, release of hormones) that vary on an approximately 24-hour cycle. Contractor/Vendor (C/V) is any company or any individual not employed by a licensee who is providing work or services to a licensee, either by contract, purchase order, oral agreement or other arrangement. Corrective Maintenance includes actions that restore-by repair, overhaul or replacement-the capability of a failed SSC to function within acceptance criteria. NRC edit NEI 06-11, Revision 2 April XXXXXX 20142016 10 Covered Individual means an individual subject to work hour controls. Any individual granted unescorted access to a nuclear power plant's protected area that who performs covered work. Covered SSC are systems, structures, and components that a Risk-Informed Evaluation Process has shown to be significant to public health and safety. The operational condition of the SSC is not relevant to the SSC covered status. See Section 20, Examples 2 and 3. Covered Work means the following: Operating or on-site directing of the operation of systems and components that a risk-informed evaluation process has shown to be significant to public health and safety

.Performing maintenance or on-site directing maintenance or performing qualityinspections of the maintenance of structures, systems, and components (SSCs) that a risk-informed evaluation process has shown to be significant to public health and safety.Performing Health Physics or Chemistry duties required as a member of the on-siteemergency response organization minimum shift complement.Performing the duties of a Fire Brigade member who is responsible for understanding theeffects of fire and fire suppressants on safe shutdown capability.Performing security duties as an armed security force officer, alarm station operator,response team leader, or watchperson, hereinafter referred to as security personnel.See Section 20, Example 4A-E.

Crew means a group of workers that are scheduled on the same shift and work together. Cumulative Fatigue means the increase in fatigue over consecutive sleep-wake periods resulting from inadequate rest. Day Off is a calendar day in which an individual does not start a work period. Deviation is a departure from the requirements included in 10 CFR 26 Subpart I.

Directing means the exercise of control over a work activity by an individual who is directly involved in the execution of the work activity, and either makes technical decisions for that activity without subsequent technical review, or is ultimately responsible for the correct performance of that work activity. See Section 20, Example 4A-E. Fatigue means the degradation in an individual's cognitive and motor functioning resulting from inadequate rest. Incidental duties means unscheduled work activities, required by the licensee, performed off-site. Increased threat condition means an increase in the protective measure level, relative to the lowest protective measure level applicable to the site during the previous 60 days, as promulgated by an NRC advisory.

Commented [A4]: See prior comments on this matter. NRC edit that performs covered work.

NEI 06-11, Revision 2 April XXXXXX 20142016 11 Maintenance means, for the purposes of Section 26.4(a)(4), the following on-site maintenance activities: modification, surveillance, post-maintenance testing, and corrective, and preventive , and predictive maintenance. Predictive maintenance activities that do not result in a change of condition or state of a risk-significant SSC may be excluded from covered maintenance activities. Examples include: nondestructive examination, thermography, vibration analysis, and data collection and analysis. Maximum Average Work Hours (MAWH) is a method for managing cumulative fatigue that establishes a limit of 54 work hours per week that an individual may average over the licensee- defined averaging period of 1 to 6 weeks. This is sometimes referred to as on-line averaging. Minimum Days Off (MDO) is a method for managing cumulative fatigue that establishes the minimum number of days off that an individual is required to have during a given period of time. The required number of days off varies by plant operating status, shift schedule

, and job duties. Nap or Restorative Sleep is a brief opportunity and accommodations for restorative, uninterrupted sleep of at least one half hour in a designated area. Nominal means the limited flexibility that is permitted in meeting a scheduled due date for completing a recurrent activity that is required under this part, such as the nominal 12-month frequency required for FFD refresher training in Section 26.29(c)(2) and the nominal 12-month frequency required for certain audits in Section 26.41(c)(1). Completing a recurrent activity at a nominal frequency means that the activity may be completed within a period that is 25 percent longer or shorter than the period required in this part. The next scheduled due date would be no later than the current scheduled due date plus the required frequency for completing the activity.

Off-site means any area not considered on-site. On-Line Averaging is an industry term synonymous with the average 54-hour-per-week limitations referred to as MAWH (Maximum Average Work Hours). On-Line Day is a day when the unit is not in an outage when the shift starts.

On-site means within the owner controlled area of the nuclear power plant. Outage Day is a day when the unit is in an outage when the shift starts. Outage Worker is a worker supporting outage activities who is not part of a multi-unit minimum control room complement required by the operating unit on the same site. Predictive Maintenance is monitoring, diagnosing or trending SSC functional or condition indicators by observation, driven by the condition of the SSC or at specified intervals. Results indicate current and future functional ability or the nature of and schedule for planned maintenance, not real-time operations. Examples of activities that may be excluded from covered maintenance activities if they do not change the state or condition of these covered SSCs include, but are not limited to, nondestructive examination (NDE), thermography, vibration analysis, and data collection and analysis. NRC edit NEI 06-11, Revision 2 April XXXXXX 20142016 12 Preventive Maintenance includes actions that detect, preclude or mitigate degradation of functional structures, systems and components (SSC) to sustain or extend its useful life by controlling degradation and failures to an acceptable level. Protected Area has the same meaning as described in 10 CFR 73.2(g): An area encompassed by physical barriers and to which access is controlled. Quality Inspections are, for the purpose of determining covered individuals, those inspection/verification activities performed during and following maintenance on covered SSCs. Excluded from covered quality inspection activities are material and fuel receipt inspections and the directing of quality inspections.

Rest Break means an interval of time that falls between successive work periods during which the individual does not perform any duties for the licensee. That portion of shift turnover that occurs outside the individual's scheduled work period may Shift turnover can be considered as part of the break. Rest break requirements are one form of work hour controls. Risk-Informed Evaluation Process means an evaluation based on a probabilistic risk analysis approach such as the Maintenance Rule (50.65(a)(4)) or other similar process. Safety-Related Structures, Systems and Components (SSCs) mean, for the purposes of this part, those structures, systems, and components that are relied on to remain functional during and following design basis events to ensure the integrity of the reactor coolant pressure boundary, the capability to shut down the reactor and maintain it in a safe shutdown condition, or the capability to prevent or mitigate the consequences of accidents that could result in potential off-site exposure comparable to the guidelines in 10 CFR 50.34(a)(1). Security Personnel are armed security force officers, alarm station operators, response team leaders, and watchpersons.

Shift Cycle means a series of consecutive work shifts and days off that is planned by the licensee or other entity to repeat regularly, thereby constituting a continuous shift schedule. Shift (Work Shift) is a regularly occurring work period

, which is normally of a consistent length (e.g., 8, 10 or 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ) and scheduled by the licensee or other entity as part of a shift schedule. Shift Schedule is a schedule that averages the hours described below over a shift cycle: Eight (8)-hour shift schedule a schedule duration that averages not more than 9 hours1.041667e-4 days 0.0025 hours 1.488095e-5 weeks 3.4245e-6 months per workday over the entire shift cycle. [Used for MDO calculations

] Ten (10)-hour shift schedule - a schedule duration that averages more than 9 hours1.041667e-4 days 0.0025 hours 1.488095e-5 weeks 3.4245e-6 months , but not more than 11 hours1.273148e-4 days 0.00306 hours 1.818783e-5 weeks 4.1855e-6 months , per workday over the entire shift cycle. [Used for MDO calculations

] Twelve (12)-hour shift schedule - a schedule duration that averages more than 11 hours1.273148e-4 days 0.00306 hours 1.818783e-5 weeks 4.1855e-6 months , but not more than 13 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , per workday over the entire shift cycle. [Used for MDO calculations

] NRC edit NEI 06-11, Revision 2 April XXXXXX 20142016 13 Shift Turnover Licensees may exclude from the calculation of an individual's work hours that portion of shift turnover that occurs outside of an individual's shiftscheduled work period. Shift turnover includes 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, arming and disarming of armed security officers, transit to and from turnover stations including compliance with radiological and personal safety requirements, and the status of ongoing activities such as extended tests of safety systems and components. The exclusion of turnover is limited to the transfer of security or safety responsibilities between two or more individuals working contiguous shifts. Shift turnover activities that may be excluded from work-hour calculations are only those activities that meet all three of the following criteria: 1.The activity immediately preceded the beginning of the individual's shift or immediatelyfollowed the end of an individual's shift;2.The activity was necessary to transfer safety and security responsibilities between two ormore individuals on contiguous shifts; and3.The activity could not have reasonably been performed during the shift because of NRCrequirements or other safety/security considerations.Tactical exercise is a force-on-force simulation used to evaluate and demonstrate the capability to defend target sets against selected attributes and characteristics of an adversary. A force-on-force tactical exercise includes all key program elements of a station's protective strategy. Unit outage means that the reactor unit is disconnected from the electrical grid.means, for purposes of this part, the period from when the reactor unit is disconnected from the electrical grid until the reactor unit achieves 75 percent reactor power or until seven calendar days have elapsed since reconnecting the reactor unit to the electrical grid whichever is shorter

. Work day means a calendar day during which an individual starts a work period.

Work hours means the amount of time an individual works performing duties for the licensee. Work hour controls are the work hour limits and rest break requirements in 10 CFR 26.205. Work hour limits, - (also referred to as Ceiling Limits) are the specific limits placed on the number of hours an individual can work within certain periods of time (24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months and 7 days), defined as the following: 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months in a 24-hour period. 26 hours3.009259e-4 days 0.00722 hours 4.298942e-5 weeks 9.893e-6 months in a 48-hour period. 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months in a 7-day period or 168 hours0.00194 days 0.0467 hours 2.777778e-4 weeks 6.3924e-5 months . shiftscheduled work period.

NRC edit is highlighted NEI 06-11, Revision 2 April XXXXXX 20142016 14 NOTE: The periods of "24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ," "48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months " and "7 days" are considered rolling time periods. Rolling means the period is not re-zeroed or the "clock reset" following a day off or after obtaining authorization to exceed the limits. The "24-hours," "48-hour

" and "7-day

" periods do not restart after a day off; the periods continue to roll.

NEI 06-11, Revision 2 April XXXXXX 20142016 15 4 POLICY AND PROCEDURES (26.203) 4.1 P OLICY The licensee shall establish a policy for the management of fatigue for all individuals who are subject to the licensee's fitness-for-duty (FFD) program and incorporate the guidance into the site or corporate written FFD policy as required in 10 CFR 26.27(b). As related to fatigue management, the FFD policy should: Address the effect of fatigue on FFD. Provide a description of any program that is available to individuals who are seeking assistance in dealing with fatigue or other problems that could adversely affect an individual's ability to safely and competently perform the duties that require an individual to be subject to this subpart. State which method of on-line work hour controls is being used, on-line Minimum Days Off (MDO) or Maximum Average Work Hours (MAWH). When complying with the on-line averaging method, state which work- hour counting system is being used relative to the start and end of the work day. See 10 CFR 26.205(d)(7)(ii). Describe the consequences of violating the policy. Describe the responsibilities of managers, supervisors and escorts to report FFD concerns. Describe the individual's responsibility to report FFD concerns. Describe the individual's responsibility to maintain his/her FFD and make self-declaration if not fit for duty.

4.2 PROCEDURES The licensee shall develop, implement, and maintain procedures that describe the: Process for implementing the work hour controls required for covered individuals. Method of on-line work hour controls that is being used, MDO (minimum days off) or MAWH (maximum average hours worked). Work hour counting system that is being used relative to the start and end of the work day, when complying with maximum average work hours. See 10 CFR 26.205(d)(7)(ii). Individuals

' and licensees

' rights and responsibilities related to self-declaration. Process to be followed when any individual covered by the FFD program 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 work period as a result of fatigue. NRC edit Individuals and licensees rights and responsibilities related to self-declaration.

NEI 06-11, Revision 2 April XXXXXX 20142016 16 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. Process to be followed if the individual disagrees with the results of a fatigue assessment that is required. Process to be followed in conducting fatigue assessments. Disciplinary actions that the licensee may impose on an individual following a fatigue assessment, and the conditions and considerations for taking those disciplinary actions. The procedures, at a minimum, delineate the following responsibilities: Operations shift manager or a site senior-level manager with requisite signature authority:

o Determining the necessity of a waiver of work hour controls for an individual to mitigate or prevent a condition adverse to safety per 10CFR Part 26

.207 (a)(1)(i).

o Maintaining staffing levels adequate to ensure that work hours can be managed consistent with the objective of preventing impairment from fatigue. Security shift manager or a site senior manager with requisite signature authority:

o Determining the necessity of a waiver of work hour controls to maintain site security per 10CFR Part 26.207 (a)(1)(e).

o Ensure staffing levels are adequate to ensure work hours are managed consistent with the objective of preventing impairment from fatigue. Plant Manager (generic title for top senior level site manager responsible for plant operations) o Responsible for ensuring a review is performed at least once per year to evaluate a full year of data evaluating the effectiveness of work hour controls. This review includes evaluation and review of: Staffing levels to ensure individual work hours are managed with the objective of preventing impairment from fatigue due to the duration, frequency or sequencing of successive work periods. The performance of individuals to ensure individual work schedules prevent s impairment from fatigue. This includes evaluating the duration, frequency , and sequencing of the hours that are worked by each individual relative to worker performance. The performance of the station in adhering to work schedules for work groups performing covered work groups: evaluate the number of schedule changes and reasons for the changes and assess whether or not schedules are being effectively implemented. Supervisor (or manager) of the individual who will be issued a waiver:

o Evaluating the employee's fitness by performing a face-to-face supervisory assessment of fitness for a waiver. NRC edit NRC edit NRC edit NRC edit The performance of the station in adhering to work schedules for covered work groups: evaluate the number of schedule changes and reasons for the

changes and assess whether or not schedules are being effectively

implemented.

NEI 06-11, Revision 2 April XXXXXX 20142016 17 o Evaluating the employee's performance and continued fitness-for-duty while working under a waiver.

o Ensuring the waiver is authorized prior to allowing an individual to exceed work hour controls being waived. NOTE: If evaluating for the issuance of a waiver and the individual's supervisor or manager is not on site, this responsibility may be performed by any manager or supervisor who is qualified to oversee the work to be performed by the individual. Department Head for departments with Covered Workers:

o Providing guidelines for overtime selection process, including those required by the union contract and the FFD requirements outlined in this guide and in the licensee's FFD Program.

o Communicating the requirements to appropriate personnel within his/her department.

o Maintaining a record of the shift schedules and shift cycles used for at least the past three years for those individuals who are subject to work hour controls. Records may be required longer than three years, if legal proceedings are ongoing. o Evaluating whether staffing levels are adequate to ensure individual work hours are managed with the objective of preventing impairment from fatigue due to the duration, frequency

, or sequencing of successive work periods. Employee (licensee or contractor):

o Evaluating his/her personal fitness to work based on impairment from fatigue.

o Managing his/her work hours consistent with the objective of preventing impairment from fatigue.

o Making a self-declaration of fatigue and discussing his/her concerns with supervision or management in cases when the individual feels his/her performance may be impaired.

o Verifying his/her working hours are correctly documented regardless of whether he/she is paid for the hours worked.

o Monitoring and reporting concerns related to other individuals' fitness to work based on impairment from fatigue (i.e., behavioral observation program).

o Being aware of the total hours worked in the previous 14 days and notifying management if work hour limits will be exceeded if asked to work additional hours. NRC edit NEI 06-11, Revision 2 April XXXXXX 20142016 18 5 MANAGING FATIGUE (26.203) 5.1 INDIVIDUAL SUBJECT TO FATIGUE MANAGEMENT Fatigue management requirements, with exception of work hour controls, apply to the following individuals: All persons who are granted unescorted access to nuclear power reactor protected areas. All persons who are required to physically report to the Technical Support Center or Emergency Operations Facility, in accordance with the site Emergency Plan and procedures. NOTE: Not all personnel that are subject to fatigue management will be subject to work hour controls. Individuals subject to work hour controls are specified in Section 6.

5.2 REQUIREMENTS Personnel subject to fatigue management will be trained and examined as part of the fitness-for-duty training requirements for the following KAs: Knowledge of the contributors to worker fatigue, circadian variations in alertness and performance, indications and risk factors for common sleep disorders, shift work strategies for that shift workers can use to obtain ing adequate rest, and the effective use of fatigue counter measures. Ability to identify symptoms of worker fatigue and contributors to decreased alertness in the workplace. NRC edit highlighted

,for that shift workers can use to ob tai n ing NEI 06-11, Revision 2 April XXXXXX 20142016 19 6 WORK HOUR CONTROLS (26.205) 6.1 INDIVIDUALS SUBJECT TO W ORK H OUR CONTROLS Any individual granted unescorted access to a nuclear power plant's protected area that who performs covered work is subject to work hour controls. These individuals shall be subject to a FFD program that meets the requirements of 10 CFR 26.4(a). See Table s 2A and 2B. If a covered individual begins or resumes performing covered work during the calculation period, the licensee shall include in the calculation of the individual's work hours all work hours worked for the licensee, including hours worked performing duties that are not considered covered work. These work hours apply to break requirements and ceiling limits as well as total hours worked for either the MDO or MAWH on-line averaging methods below. At a multi-unit site when one or more units is in an outage, only those licensed operators composing the minimum shift complement of operators required in the table below derived from 10 CFR 50.54(m) are required to work under the on-line (MAWH or MDO) hours rules. Minimum Number of Individuals Per Shift Working Non

-outage Schedules for Onsite Staffing of Operating Nuclear Power Units during Outages Number of operating nuclear power units 1 Position Two-unit Site Three-unit Site One Control Room Two Control Room Two control rooms ThreeControlRooms SingleControl Room Unit InOutage Single ControlRoom Unit andOne Unit Servedby Dual ControlRoom InOutage One of the Units Servedby DualControlRoom in OutageTwo Units Servedby DualControlRoom in Outage One Senior Operator 2 2 2 2 2 Operator 2 2 2 2 2 Two Senior Operator 2 3 3 Operator 32 4 4 1 For the purpose of this table, a nuclear power unit is considered to be operating when it is connected to the grid.

NRC edit NEI 06-11, Revision 2 April XXXXXX 20142016 20 If a worker (any classification) is dedicated to and solely working the operating unit, that worker is not eligible for outage work hour rules. In fuel handling operations, the operators making and approving reactivity changes are required to be on operations work hours rules if using the MDO method. At a minimum, this includes the operator on the manipulating bridge over the reactor vessel the fuel handling SRO in containment, and the control room reactor operator on the tag board (or equivalent). All others involved with fuel handling operations may be considered under the maintenance work hour rules. Predictive Maintenance on a covered system may be a covered activity. Predictive maintenance activities that do not result in a change of condition or state of a risk-significant SSC may be excluded from covered maintenance activities. Examples include: nondestructive examination, thermography, vibration analysis, and data collection and analysis. If a change in condition or operational state of the equipment is necessary, the actual operation or maintenance activity to prepare for the predictive maintenance activity may be covered. Emergency response personnel who do not perform health physics or chemistry duties required as a member of the on-site emergency response organization minimum shift complement are not covered workers. For the purposes of determining the performing or directing of covered work, the following guidance should be applied: Operating or on-site directing of the operation of systems and components that a risk-informed evaluation process has shown to be significant to public health and safety. Performing maintenance or on-site directing of the maintenance or performing quality inspections during and following maintenance on systems, structures and components (SSCs) that a risk-informed evaluation process has shown to be significant to public health and safety. Maintenance includes the following on-site maintenance activities: modification, surveillance, post-maintenance testing, and corrective

, and preventive, and predictive maintenance of SSCs. Only maintenance activities that change the operational condition or state of the SSCs are included. Directing is the exercise of control over a maintenance or operations covered work activity by an individual who is directly involved in the execution of the work activity and either makes technical decisions for that activity without subsequent technical review or is ultimately responsible for the correct performance of that work activity. Miscellaneous interpretations:

oScaffolding - Erecting scaffolding is not considered a covered activity.NRC edit NRC edit NRC edit NRC edit NEI 06-11, Revision 2 April XXXXXX 20142016 21 o Crane operations are often covered activities if part of covered work or operations dealing with safe load lifts as defined by NUREG 0612.

o Insulation - Removal of insulation is not a covered activity. However, restoration of insulation material that brings a covered SSC back into compliance with its design is covered work. Commented [A5]: Suggest removing or clarifying this sub-bullet on the grounds that insulation removal may be a covered activity in some locations.

NEI 06-11, Revision 2 April XXXXXX 20142016 22 6.2 W ORK HOUR SCHEDULING REQUIREMENTS AND PRINCIPLES (26.205 (C)) Licensees shall schedule the work hours of covered individuals consistent with the objective of preventing impairment from fatigue due to the duration, frequency or sequencing of successive work periods. When establishing schedules the following should be applied consistent with the performance objective of preventing impairment from fatigue due to the duration, frequency or sequencing of successive work periods: Duration of scheduled work period (not to exceed 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ). Duration of break periods. Consistent start times for work periods Considerations of start times consistent with circadian factors. Consistent stop times for work periods. Consistent rotation (e.g., if working a 5-week shift cycle, the scheduled work days and days off are repeated every five weeks). Rotating schedules provide suitable transition between shifts (days/nights, days/swings/nights), 8-hour shift rotations rotate forward or provide more than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months between work periods to adjust circadian rhythm; 12-hour shift rotations provide 34 hours3.935185e-4 days 0.00944 hours 5.621693e-5 weeks 1.2937e-5 months off during day/night transitions. Long- range predictability is a key aspect of fatigue mitigation. Circadian factors. Training requirements. Vacation scheduling. Consideration of the impact of unscheduled overtime. Stable 24-hour shift rotation (e.g., 3 X 8's, 2 X 12's, 2 X 10's with four hours un-staffed). The impact of backward shift rotation (rotation of the start of the shift from days to night to swings). Staffing levels should be sufficient so that schedules for the covered individuals can be maintained based on vacation and training demand without relying on waivers. It is expected and allowed that normal variation in vacation and training demands may occasionally require additional work hours to be used. Management is responsible for understanding the total vacation, training and workload demands and for maintaining sufficient staff to do the work. NRC edit Long range predictability is a key aspect of fatigue mitigation.

NEI 06-11, Revision 2 April XXXXXX 20142016 23 6.3 W ORK HOUR CONTROLS The first step in the fatigue management process is to identify all reasonably foreseeable factors that could contribute to worker fatigue. A variety of factors which can be cumulative, contribute to whether an individual experiences fatigue as well as the severity of that fatigue. The factors can include work scheduling, circadian adjustments, job demands, cumulative fatigue, acute fatigue 1 and sleep deprivation. In addition to carefully constructed work schedules and proper staffing, fatigue is managed by two basic strategies, limiting hours worked and mandating required break periods (also referred to as "rest breaks"). This is accomplished via scheduling protocols to limit both acute and cumulative impact. Work Hour Limits (Ceiling Limits) and Break Requirements - (Rest Breaks) Work hour limits (ceiling limits) are defined as the following: 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months in a 24-hour period. 26 hours3.009259e-4 days 0.00722 hours 4.298942e-5 weeks 9.893e-6 months in a 48-hour period. 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months in a 7-day period or 168 hours0.00194 days 0.0467 hours 2.777778e-4 weeks 6.3924e-5 months . Ceiling limits and break requirements always apply when a worker is a covered individual except when specifically exempted in Section 12, Exceptions. 6.3.1 Applying Work Hour (Ceiling) Limits The periods of "24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ", "48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months " and "7-days" are considered rolling time periods. Rolling means the period is not re-zeroed or the "clock reset" following a day off or after obtaining authorization to exceed the limits. The "24-hour","48-hour" and "7-days" periods do not restart after a day off; the periods continue to roll. See Section 20, Example 7. 6.3.2 Applying Break Requirements Minimum work period break is 10-hour break between the previous work period, or an 8-hour break between the previous work period when a break of less than 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months was is necessary to accommodate a crew's shift schedule d transition from a unit or security system outage or increased threat condition to operationbetween work schedules or shifts. Minimum 9-day break requirement is a 34-hour break in the preceding 216-hour (9-day) period. When determining the 34-hour break in 9 days, a rolling 216-hour (9-day) period should be used.

1 Acute fatigue results from short-term sleep loss or from short periods of heavy physical or mental work. The effects of acute fatigue are of short duration and usually can be reversed by sleep and relaxation. NRC edit NEI 06-11, Revision 2 April XXXXXX 20142016 24 The licensee should continuously look forward from the start of the first period of work, immediately following a 34-hour break, to ensure there is a 34-hour break is scheduled in the subsequent 9 days or 216-hour period. Conversely, to ensure that the actual hours worked by the individual are in compliance, the licensee must verify that the individual has had a 34-hour break in the previous 9 days or 216-hour period at the end of the work period. When calculating the duration of a break between work periods, that portion of shift turnover that occurs outside the individual's scheduled work period may be included as part of the break periodduration,.

When necessary to accommodating accommodate a scheduled crew transition between rotating shift periods to a new work schedule (e.g., 10-hour shifts to 12-hour shifts) then a break period of 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months is acceptable for a crew's transition from a an unit or security system outage or increased threat condition to online operations, a break of 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months may be allowed between work periods

.2 Break times may be required to be extended based on the travel time provisions in Section 7, Counting Work Hours and Break Times.

6.4 METHODS OF W ORK HOUR CONTROLS Work hour limits are prescribed by either minimum days off (MDO) or maximum average work hour (MAWH) protocols.

The MDO method requires that in a shift cycle, the worker will receive an average number of days off equal to or greater than the MDO requirement for the applicable shift schedule. 6.4.1 Minimum Days Off (MDO) The on-line MDO method requires that in a shift cycle, the worker will receive an average number of Days Off per week equal to or greater than the MDO requirement for the shift schedule that applies. Covered Individual 8-hour shift 10-hour shift12-hour shiftActual Average Shift Hours 8 to less than or equal to 9 hours1.041667e-4 days 0.0025 hours 1.488095e-5 weeks 3.4245e-6 months Greater than 9 to less than or equal to 11 hours1.273148e-4 days 0.00306 hours 1.818783e-5 weeks 4.1855e-6 months Greater than 11 and less than or equal to 13 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Maintenance 1 day off per week 2 days off per week 2 days off per week Operations, HP, Chemistry, Fire Brigade 1 day off per week 2 days off per week 2.5 days off per week 2 Ref: Federal Register/ Vol 73 No 62. Page 17133, Section 26.205(d)(2)(i) - break period applies to a crew transition. NRC edit NRC edit NRC edit NEI 06-11, Revision 2 April XXXXXX 20142016 25 Security 1 day off per week 2 days off per week 3 days off per week The planned shift schedule is used to establish the beginning minimum days off (MDO) requirement. If the actual hours worked do not deviate from the planned shift schedule, the required MDO will not change. Periodically, workers and supervisors may need to work unscheduled hours to meet station needs. An accumulation of unscheduled work hours over a shift cycle may affect the MDO requirement that applies to individuals or crews. The table provided is for a shift cycle schedule that is averaged over 42 days or fewer as applicable. If the worker averages more hours than previously scheduled the licensee must recalculate the average hours worked per shift to ensure the proper MDO (8, 10 or 12) is met prior to the end of the shift cycle. For actual shift rotation cycles greater than 42 days, the averages must be calculated over a period of 42 days or fewer. The licensee may elect to use a rolling or fixed (maximum) six-week period for the purposes of determining the minimum days off. The actual repeatability of the schedule rotation may exceed 6 weeks; however, the shift cycle used for calculating the minimum days off cannot exceed 6 weeks. Generally a rolling evaluation period for MDO evaluations takes into account the current day and looks back at the previous days in the evaluation period for compliance. For example, an individual on a 42-day (six-week) rolling evaluation period-for the purpose of compliance with the MDO requirement-he current day and the last 41 days of actual time are used to determine if the individual has had the required days off. When tomorrow is reached, it is that day and the previous 41 days, etc. For the purposes of predicting compliance, the current day and the next 41 days of scheduled time are used. For a 42-day (six-week) fixed calculation period, an individual must meet the MDO requirement for their job function and average shift length for days 1 to 42. The day following day 42 is a new day 1, and a new 42-day evaluation period begins. These evaluation periods go in blocks from 1-42 and then start over. Once the schedule goes beyond day 42, the evaluation period looks ahead another 42 days and does not look back as does the rolling evaluation method. Guidance for details on administration of the MDO method is in Section 9.

NEI 06-11, Revision 2 April XXXXXX 20142016 26 6.4.2 Maximum Average Work Hours (MAWH) aka On Line Averaging Method The alternative approach to on-line MDO is a weekly maximum average of 54 hours6.25e-4 days 0.015 hours 8.928571e-5 weeks 2.0547e-5 months worked, referred to as MAWH based on a rolling averaging period of up to 6 weeks. This alternative is applicable to all covered workers, regardless of classification. In a rolling period: The averaging period starts "rolling" after a work history for a covered worker has been established equal to the length of the averaging period. The averaging period rolls by one full week at a time. The week does not have to start on any specific day but must be consistent through the calculation period and documented in the controlling procedure. Shifts that bridge the point in time during the week when the averaging period rolls forward one week may be counted in one of two ways and the method must be documented in the controlling procedure:

o The hours for that shift may be included in the week the shift starts.

o The hours may be included in the weeks the hours are worked.

6.5 DEVIATIONS AND COMPLIANCE A covered worker must be in compliance with all the specific work hour rules or be under an approved waiver prior to performing covered work. Whenever a covered worker finds that a violation of limits exists, then in order to reset from that deviation to permit further covered work, the worker must come into compliance with all: Break requirements. Ceiling limits. The specific rules for the method of work hour calculation below prior to performing any further covered work. Each deviation must be documented in the licensee corrective action program: Resets from deviations under MDO must additionally ensure that actions are in place to comply with MDO requirements by the end of the shift cycle if using the fixed-cycle method in work hour calculations. Resets from deviations under MAWH must additionally ensure that actions are in place to comply with the 54-hour averaging limit by the end of the averaging period.

NEI 06-11, Revision 2 April XXXXXX 20142016 27 7 COUNTING WORK HOURS AND BREAK TIME (26.205) 7.1 P ROCESS FOR EVALUATING A SCHEDULE This section orients the reader to how schedules are structured and gives some general strategies for reading them. Schedules are typically fixed or rotating, where operations, RP and chemistry will usually follow the same schedule, while maintenance and security will typically follow a fixed schedule. Examples of on-line schedules: Operations (5-section typical) D = Day 12-hour, N = Night 12-hour T = Training 10-hour Crew/Da y1234567891011121314151617181920212223242526272829303132333435MTWTFSSMTWTFSSMTWTFSSMTWTFSSMTWTFSS1TTTTNNNDDDNNNNDDDD2NNNDDDNNNNDDDDTTTT3DDDNNNNDDDDTTTTNNN4NNNNDDDDTTTTNNNDDD5DDDDTTTTNNNDDDNNNN Security (4-section typical) Crew/Day1234567891011121314151617181920212223242526272829303131333435DayMTWTFSSMTWTFSSMTWTFSSMTWTFSSMTWTFSSADDDD DDDD DDDD DDDD DDDB DDDDDDDD DDDDDDDDCNNNNNNNNNNNN NNNN NNND NNNN NNNNNNNN NNNN Maintenance may follow a standardized day or night protocol or work to a schedule similar to those illustrated. When a schedule is created or schedule change is proposed, the following items need to be considered prior to implementation: Begin by evaluating the existing and proposed schedule for continued compliance with restrictions of the rule (required breaks, consecutive days worked, transitioning, current work schedules, etc.) Items to be considered during schedule development: Self-relieving shifts (absorb unexpected absences). Minimizing changes (make schedules compliant with minimal changes). Eight-hour shifts vs. 10- or 12-hour shifts. Union contracts.

NEI 06-11, Revision 2 April XXXXXX 20142016 28 Cumulative fatigue impacts. Ability to fill an unexpected vacancy on any shift assuming the maximum allowable personnel are on vacation.

7.2 ACCOUNTING OF WORK H OURS Work hours mean the amount of time an individual performs duties for the licensee. This includes all work hours, with the following exceptions: That portion of sShift turnover that occurs outside the individual's scheduled work period time may be excluded. Within-shift break and rest periods in which there is reasonable opportunity and accommodations for restorative sleep (e.g., a nap) may be excluded. Unscheduled work hours for the purpose of participating in unannounced emergency preparedness exercises and drills may be excluded.

The time the individual works unscheduled work hours for the purposes of responding to a declared plant emergency, as defined in the licensee's emergency plan. Resuming or beginning covered work means the act of performing covered work, whether considered part of an earlier work day or resumption of covered work activities. If an individual begins or resumes performing for the licensee any covered work during the calculation period, the licensee shall include in the calculation of the individual's work hours all work hours worked for the licensee, including hours worked performing duties that are not covered work. Exclusion and Inclusion Guidance for Work Hour Calculations Paid time not included in the work hour calculations: Only the actual hours worked are included in the work hour calculations. Examples of paid hours not worked are as follows: Vacation time is time away from work and is not included in the work hour calculation. Sick leave is time away from work and is not included in the work hour calculation. Personal leave is time away from work and is not included in the work hour calculation. Holiday pay may be either time away from work or at work. If the time is at work, then only the actual hours worked are included in the work hour calculation. Declared plant emergencies as defined in the licensee's emergency plan: For the purposes of compliance with § 26.205(c) and (d), licensees may exclude from the calculation of an individual's work hours the time the individual works unscheduled work Formatted: Bulleted + Level: 1 + Aligned at: 0.25" +Indent at: 0.5"Commented [A6]:

D elet e the final bullet regarding work hours during an emergency. A rule change would be necessary to permit excluding those work hours. Under 26.207(d), the work hour controls in 26.205(c) and (d) do not apply. However, the work hours must be counted. NRC edit NRC edit NRC deletion of NEI added bullet NEI 06-11, Revision 2 April XXXXXX 20142016 29 hours3.356481e-4 days 0.00806 hours 4.794974e-5 weeks 1.10345e-5 months for the purposes of responding to a declared plant emergency, as defined in the licensee's emergency plan. When the plant exits the emergency classification to a non-emergency state, this exclusion becomes not applicable. Licensees should evaluate the need for waivers and performing supervisory assessments of fitness. This exclusion applies to ceiling limits, break requirements, MDOs and MAWH limits. Unannounced emergency preparedness exercises and drills: Licensees may exclude the time an individual works unscheduled work hours for the purpose of participating in the actual conduct of an unannounced emergency preparedness exercise or drill. If an individual is on a day off, it is still considered a day off. Force-on-force tactical exercises: For those licensees using MDO: Licensees may exclude shifts worked by security personnel during the actual conduct of force-on-force tactical exercises evaluated by the NRC when calculating the individual's number of days off. This includes security support personnel who may not be actual drill participants but does not include individuals providing the normal security function while the drill is occurring. For those licensees using MAWH: Licensees may exclude shifts worked by security personnel during the actual conduct of NRC-evaluated force-on-force tactical exercises when calculating average hours worked. This includes security support personnel who may not be actual drill participants but does not include individuals providing the normal security function while the drill is occurring. See Table 7 for additional guidance. Common defense and security: Licensees need not meet the work hour requirements when informed in writing by the NRC that these requirements, or any subset thereof, are waived for security personnel in order to assure the common defense and security, for the duration of the period defined by the NRC. Daylight Saving Time: When working during the change from standard time to daylight savings time, the shift being worked during the time change may be counted as a 7-hour, 9-hour, or 11-hour shift. When working during the change from daylight savings time back to standard time, the shift being worked during the time change may be counted as an 8-hour, 10-hour, or 12-hour shift (i.e., the additional hour does not have to be included in the work hour calculations). In addition to not counting the extra hour, the evaluation period (i.e., 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months , 168 hours0.00194 days 0.0467 hours 2.777778e-4 weeks 6.3924e-5 months or 7 calendar days should not be impacted by the decrease or increase in actual time versus apparent time.

Commented [A7]:

D elet e this bullet for the reasons discussed above (would require a rule change) and re-insert the deleted bullet regarding exiting an emergency. NRC edit NRC edit NEI 06-11, Revision 2 April XXXXXX 20142016 30 Call-in work period: A call-in is considered an addition to the normal work schedule. The work hours can be accounted for using three different methods depending on timing and circumstances of the call-in work period.

o The call-in hours can be considered a separate work period. Using this method, only the hours worked for the licensee will be counted. The method requires a 10-hour break before the call in period and after the call-in period.

o The call-in hours can be considered an extension to the preceding or succeeding work period. Using this method, the intervening hours of the extended work period must be counted.

o A waiver can be processed for the required 10-hour break between successive work periods. The requirements of Section 9, Waivers, apply to this method. See Section 20, Examples 8 and 9. Incidental duties performed off site: Licensees may exclude from the calculation of an individual's work hours unscheduled work performed off-site (e.g., technical assistance provided by telephone from an individual's home or an unscheduled teleconference, calls between the licensee and a vendor or between parties on behalf of the licensee) provided the total cumulative duration of the work, which is required by the licensee, does not exceed a nominal 30 minutes during any single break period. Time spent on short-duration, infrequent or irregular telephone calls that do not interrupt a sleep period to verify or discuss plant and equipment status may be excluded, provided the cumulative duration of these calls does not exceed a nominal 30 minutes during any single break period.

For the purposes of compliance with the minimum break requirements and the minimum day off requirements, such duties (work periods less than nominal 30 minutes) do not constitute work periods or work shifts. Professional time is not discouraged, for example after-hours study time that is not required by the licensee may be excluded from work-hour calculations. As with any academic setting and curriculum, after-hours study time varies from individual to individual. Appropriate after-hours study time complements the utility provided training to ensure the learning process occurs and optimal information retention is achieved. This does not include short-duration, infrequent or irregular telephone calls that do not interrupt a sleep period to verify or discuss plant and equipment status, provided the cumulative duration of these calls does not exceed a nominal 30 minutes during any single break period. See Section 20, Examples 10, 11, 12 and 17. Shift duration extensions (holdovers): When considering shift extensions for individuals performing covered work, all hours worked by the individual shall be included. For example, if an individual has performed NRC edit NRC edit NEI 06-11, Revision 2 April XXXXXX 20142016 31 15 hours1.736111e-4 days 0.00417 hours 2.480159e-5 weeks 5.7075e-6 months of non-covered work, and the individual is needed to perform additional covered work that extends beyond 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months in a 24-hour period, then a waiver to exceed the work hour limits shall be approved prior to the individual exceeding the 16-hour limit. On the other hand, if the individual has performed 14 hours1.62037e-4 days 0.00389 hours 2.314815e-5 weeks 5.327e-6 months of covered work and is needed to perform additional non-covered work, then the programmatic approvals of this document do not apply. However, the additional work hours are included in consideration of any other limits if the individual subsequently performs covered work. Official union time: Unpaid Union business is considered personal time and not counted in work hour calculations (including no impact to breaks and ceiling limits). Grievance meetings held pursuant to a contract between the Union and the licensee where personnel are required to be in attendance are considered time that must be considered in work hour calculations. Travel time: Travel time that is required by the licensee is work performed for the licensee.

o Should the worker be required to travel to another work location within the same licensee organization, the licensee needs to count the travel time in the work hour calculation. by applying the following:

o Travel time that is required by the licensee and occurs wholly within an individual's normally scheduled work period should be counted as work hours and may be treated as time performing non-covered duties when applying work hour controls

. o A normal daily commute is not considered to be work performed for the licensee and should not be included in the calculation of work hours. Should the worker be required to travel to another work location, a nominal difference in the commute of 30 or fewer minutes need not be included in the calculation of work hours. Similarly, should the worker be required to travel to another work location within the same licensee organization that does not incur additional travel time using an established method, may be treated as a daily commute with no additional accrual of work hours. o If the worker is required to extend his/her shift schedule by traveling (either at the end or beginning of a work period), then extend the work period hours by the nominal travel time and apply the minimum break and ceiling rules accordingly. This time may be treated as non-covered work hours, when applying work hour controls... o If the worker is required to travel on his/her own time, wholly outside of a normal work period, then consider this an extension to the preceding or succeeding work period and increase the minimum break time (either the minimum work period break of 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months or minimum 9-day break requirement as appropriate) by the NRC edit highlighted NRC edita nominal d NEI 06-11, Revision 2 April XXXXXX 20142016 32 nominal travel time to ensure adequate opportunity for a full rest period.

oNominal The amount of travel time counted as work hours should be the time thatthe individual actually spends completing the travel, including any involuntary stops or diversions that were for reasons beyond the control of the traveler (e.g., weather and traffic). For planning purposes, and for trips that include voluntary stopovers or diversions (e.g., leisure travel), travel time from the point of origin to the destination without stopovers or diversions may be estimated,travel time is determined using an established Web-based mapping application.

See Section 20, Examples 5 and 6. Shift turnover: Licensees may exclude from the calculation of an individual's work hours that portion of shift turnover that occurs outside of an individual's shift. Shift turnover includes those activities that are necessary to safely transfer information and responsibilities between two or more individuals preceding a shift or immediately following a shift. Shift turnover activities may include, but are not limited to, discussions of the status of plant equipment, arming and disarming of armed security officers, transit to and from turnover stations including compliance with radiological and personal safety requirements, and the status of ongoing activities such as extended tests of safety systems and components.

oShift That portion of shift turnover that occurs outside the individual's scheduledwork period may be excluded from the calculation of an individual's shift work hours, provided that the time excluded is limited to those activities necessary to transfer information and responsibilities between two or more individuals working contiguous shifts. oThe exclusion of turnover is limited to the transfer of security or safetyresponsibilities between two or more individuals working contiguous shifts.

oHoldover time to cover for a late arrival or an early arrival for a meeting orspecial evolution may not be considered part of turnover and must be included in work hour calculations. See Section 20, Examples 18A, B, C and D.

7.3 DAYS O FF A day off is a calendar day in which an individual does not start a work shift. Individuals may change shift schedules during the shift cycle. The following guidance applies: For shift schedule transitions, licensees should calculate the average duration of the shifts worked and to be worked during a period of not more than six weeks that encompasses the schedule transition to determine the applicable day off requirement. If the average Commented [A8]: Revision suggested to avoid using "nominal" in two different ways within the document. NRC edit NRC edit NRC edit NEI 06-11, Revision 2 April XXXXXX 20142016 33 shift schedule is not more than 9 hours1.041667e-4 days 0.0025 hours 1.488095e-5 weeks 3.4245e-6 months , then the minimum day off requirements for eight-hour shift schedules would apply. If the average shift schedule is more than nine hours but not more than 11 hours1.273148e-4 days 0.00306 hours 1.818783e-5 weeks 4.1855e-6 months then the requirements for a 10-hour shift would apply. If the average shift schedule is more than 11 hours1.273148e-4 days 0.00306 hours 1.818783e-5 weeks 4.1855e-6 months then the requirements for a 12-hour shift apply. The following guidance should be applied in determining if a day off has been provided: For security personnel during the actual conduct of force-on-force tactical exercises evaluated by the NRC, if security personnel work on his/her day off, this work day may be counted as a day off in the calculation of minimum days off. Licensees may exclude from the calculation of an individual's work hours the time the individual works unscheduled work hours, above the normal scheduled work hours, for the purpose of participating in the actual conduct of an unannounced emergency preparedness exercise or drill. If an individual is on a day off, it is still considered a day off. Licensees may exclude from the calculation of an individual's work hours unscheduled work performed off-site (e.g., technical assistance provided by telephone from an individual's home) provided the total duration of the work, which is required by the licensee, does not exceed a nominal 30 minutes during any single break period. For the purposes of compliance with the minimum break requirements and the minimum day off requirements, such duties do not constitute work periods or work shifts. After-hours study time during training weeks shall be excluded from work hour calculations. As with any academic setting and curriculum, after-hours study time varies from individual to individual. Appropriate after- hours study time complements the utility provided training to ensure the learning process occurs and optimal information retention is achieved. Activities initiated by the individual (not required by the licensee) may be performed at home on a day off and not be considered "work," (e.g., studying, reading work-related material, reading email).

NEI 06-11, Revision 2 April XXXXXX 20142016 34 TABLE 7: WHAT TO INCLUDE/EXCLUDE W HEN CALCULATING W ORK H OURS [See rule for details - table provides only general summary of the rule] Sub-section Item Must Include May Exclude 26.205(b) Performing duties for licensee Must include amount of time individual performs duties for the licensee, including from off-site locations in some circumstances (see below 26.205(b)(5)) May exclude off-hours voluntary study time, as long as it is not required or performed for the licensee (from Reg Guide 5.73

) 26.205(b)(1) Shift Turnover Must include (examples; not exhaustive list):

Hours worked during turnovers between individuals within a shift period due to rotations or relief within a shift Shift holdovers to cover for late arrivals of incoming shift members Early arrivals for meetings, training, or pre-shift briefings for special evolutions Holdovers for interviews needed for event investigations May exclude:

That portion of ose activities necessary to safely transfer information and responsibilities between contiguous shifts that occurs outside an individual's scheduled work period Arming and disarming for security personnel (from Reg Guide 5.73

) Personnel donning/doffing radiation protective gear and transiting to and from a job site where continuous monitoring is required, which also limits this exclusion to turnover activities between contiguous shifts 26.205(b)(2) Within-shift break and rest periods Must include break or rest periods during which there is no reasonable opportunity andaccommodation for restorative sleep, such as most lunch breaks May exclude that portion of a break or rest period during which there is reasonable opportunity and accommodation for restorative sleep 26.205(b)(3) Beginning or resuming duties subject to work hour controls Must include (count) all hours performing duties for the licensee, including hours worked on duties that are not subject to work hour controls if the individual performs any covered duties during the calculation period The hours worked before the beginning or resumption of covered work are not subject to work hour controls themselves, even though they must be included in the count once covered work is begun or resumed NRC edit NEI 06-11, Revision 2 April XXXXXX 20142016 35 Sub-section Item Must Include May Exclude 26.205(b)(4) Unannounced emergency preparedness exercises and drills Must include hours spent preparing for the exercises and drills, but only if the individual also performs covered duties during the calculation period May exclude from calculation the unscheduled work hours to participate in the actual conduct of such exercises or drills 26.205(b)(5) Incidental duties performed off site Separate unscheduled phone calls that together exceed the nominal 30 minutes (e.g., 2 phone calls of 20 min. each, 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months apart) must be included as a separate work period or as part of a previous or upcoming work shift May exclude unscheduled work performed off site if total duration does not exceed nominal 30 minutes during any single break period; such unscheduled This work also does not constitute "work periods" or "work shifts" when calculating rest breaks or MDOs (From NRC Guidance) Travel time Must include travel time in cases where:

The individual is performing work for the licensee The travel is in excess ofthe individual's regular

commute May exclude travel time if:

The individual is not performing work for the licensee The travel is no longer than, or is part of the individual's regular commute Individual has initially reported to the site to begin work and has not yet been granted unescorted access Travel time that is not directed by the licensee may likewise be excluded 26.207(b) Force-on- force tactical exercises exception Must include hours spent preparing for the exercises and drills, but only if the individual also performs covered duties during the calculation period May exclude shifts worked by security personnel (may or may not be actual drill participants) during the actual conduct of NRC-evaluated force-on-force tactical exercises when calculating individual's number of days off (as per MDO requirements, or when calculating weekly average hours worked (as per the MAWH requirements). The exclusion does not apply to security personnel providing security for the facility during the exercises.** ** In practice, licensees should exclude from the calculation of hours worked during the actual conduct of NRC-evaluated force-on-force tactical exercises only those hours worked in excess of 54 hours6.25e-4 days 0.015 hours 8.928571e-5 weeks 2.0547e-5 months during the week of the exercise.

Formatted TableNRC edit NRC edit NEI 06-11, Revision 2 April XXXXXX 20142016 36 8 APPLICATION OF MINUMUM DAYS OFF (MDO) AND/OR MAXIMUM AVERAGE (MAWH) WORK HOURS ALTERNATIVE (26.205 (D)(3),(D)(7)) NOTE: Ceiling limits and break requirements apply to covered workers under all circumstances when determining work hours to be worked unless waived or specifically exempted. See Section 7 and Table 7 for specific guidance on exclusions and inclusions impacting work hour calculations.

8.1 GENERAL INFORMATION In order to prevent workers from experiencing the effects of cumulative fatigue, a licensee may implement the minimum days off (MDO) or maximum average work hours (MAWH) protocol. A licensee may not utilize a combination of the two protocols simultaneously (e.g., operations staff on MDO and maintenance staff on MAWH). During unit outages and planned security system outages, a licensee may implement either method of fatigue management. This may differ from the on-line protocol (e.g., on line may be using MAWH, where in an outage the MDO method would normally be employed). Station policies should delineate the chosen method for applying work hour controls to manage fatigue during on-line and outage conditions. The following guidance applies to both MDO and MAWH methods of work hour control: Work hours are calculated as the amount of time an individual performs any duties for the licensee including but not limited to the following:

o All within-shift break times and rest periods during which there is no reasonable opportunity or accommodations appropriate for restorative sleep (e.g., a nap).

o Shift holdovers to cover for late arrivals of incoming shift members.

o Early arrivals of individuals for licensee required meetings, training or pre-shift briefings for special evolutions. (These activities are not considered shift turnover activities.)

o Holdovers for interviews needed for event investigations. Within-shift breaks and rest periods:

o Time spent at lunch, although non-productive, is included in the work hour calculations.

o Break time allowed during the scheduled work day is included in the work hour calculation.

o That portion of a break or rest period during which there is a reasonable opportunity and accommodation for restorative sleep on site (e.g., a nap of at least 30 minutes) mmay be excluded. NRC edit may be excluded.

NEI 06-11, Revision 2 April XXXXXX 20142016 37 Shift turnover:

o Licensees may exclude that portion of shift turnover that occurs outside the individuals scheduled work period from the calculation of an individual's total work hours.

o The level of precision in determining the time duration for turnover should not be greater than 15 minutes.

8.2 MINIMUM DAYS OFF (MDO) METHOD Minimum Day Off (MDO) MDO is a method for managing cumulative fatigue that establishes the minimum number of days off that must be taken in order to comply with the appropriate on-line or outage work hour controls. The required number of days off varies by plant operating status, shift schedule

, and job duties. Applying MDO Method The licensee may elect to use a rolling or fixed (maximum of) six-week period for the purposes of determining the minimum days off. The actual repeatability of the schedule rotation may exceed six weeks; however, the shift cycle used for calculating the minimum days off cannot exceed six weeks. Generally a rolling evaluation period for MDO evaluations takes into account the current day and looks back at the previous days in the evaluation period for compliance. For example, an individual on a 42-day (six-week) rolling evaluation period-for the purpose of compliance with the MDO requirement-the current day and the last 41 days of actual time are used to determine if the individual has had the required days off. When tomorrow is reached, it is that day and the previous 41 days, etc. For the purposes of predicting compliance, the current day and the next 41 days of scheduled time are used. For a 42-day (six-week) fixed evaluation period, an individual must meet the MDO requirement for their job function and average shift length for days 1 to 42. The day following day 42 is a new day 1 and a new 42-day evaluation period begins. These evaluation periods go in blocks from 1-42 and then start over. Once the schedule goes beyond day 42, the evaluation period looks ahead another 42 days and does not look back like the rolling evaluation method does. NRC edit NEI 06-11, Revision 2 April XXXXXX 20142016 38 The on-line MDO method requires that in a shift cycle, the worker will receive an average number of Days Off per week equal to or greater than the MDO requirement for the shift schedule that applies. Covered Individual 8-hour shift 10-hour shift 12-hour shift Actual Average Shift Hours 8 to less than or equal to 9 hours1.041667e-4 days 0.0025 hours 1.488095e-5 weeks 3.4245e-6 months Greater than 9 to less than or equal to 11 hours1.273148e-4 days 0.00306 hours 1.818783e-5 weeks 4.1855e-6 months Greater than 11 and less than or equal to 13 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Maintenance 1 day off per week 2 days off per week 2 days off per week Operations, HP, Chemistry, Fire Brigade 1 day off per week 2 days off per week 2.5 days off per week Security 1 day off per week 2 days off per week 3 days off per week The planned shift schedule is used to establish the beginning minimum days off (MDO) requirement. If the actual hours worked do not deviate from the planned shift schedule, the required MDO will not change. Periodically, workers and supervisors may need to work unscheduled hours to meet station needs. An accumulation of unscheduled work hours over a shift cycle may affect the MDO requirement that applies to individuals or crews. The above table is for a shift schedule that is averaged over a shift cycle of 42 days or less as applicable. If the worker averages more hours than previously scheduled the licensee must recalculate the average hours worked per shift to ensure the proper MDO (8, 10 or 12) is met prior to the end of the shift cycle. For actual shift rotation cycles greater than 42 days, the averages must be calculated over a period of 42 days or less. If the individual works for a licensee for a period less than one week, the MDO requirement is not applicable. Calculating Work Hours Using the MDO Method Licensees shall ensure that individuals have, at a minimum, the number of days off specified for their shift schedule. Resets from deviations must additionally ensure that actions are in place to comply with MDO requirements by the end of the shift cycle if using the fixed-cycle method in work hour calculations.

NEI 06-11, Revision 2 April XXXXXX 20142016 39 Transitions Between On-Line Schedules Licensees may transition individuals or crews between shift schedules by ending a shift cycle and starting a new shift cycle with a different shift schedule. The following guidance applies: Terminating the shift cycles: Ensure that the individuals meet the MDO requirement applicable to the shift schedule that the individuals were working before it was terminated. In these instances, for the purpose of determining compliance with the MDO requirements, the licensee may average the individuals' work hours over a period immediately preceding the transition that is equal in length to the shift cycle the individuals were working before the transition (e.g., six weeks, if the shift cycle was six weeks in length). The licensee should then ensure that the individual meets the applicable MDO requirement for the new shift schedule going forward from the beginning of the new shift cycle. A shift cycle may be as short as one week. There are no MDO requirements for individuals working for the licensee forshift cycles fewerless than seven days. Transitions Between On-Line and Outage Schedules The ceiling and break requirements apply during the transitions. The outage MDOs only apply while in a unit outage or planned security system outage. For unit outages, o. On-line MDO rules take effect the first shift after the reactor unit achieves 75 percent reactor power or until seven calendar days have elapsed since reconnecting reconnects the reactor unit to the electrical grid , whichever is shorter. For the first 42 days after an outage (for six-week cycles), the employee must be evaluated using the fixed shift cycle method. Transitions Between Covered Groups or Onto a Covered Shift If an individual begins or resumes performing for the licensee any covered work during the calculation period, the licensee shall include in the calculation of the individual's work hours all work hours worked for the licensee, including hours worked performing duties that are not covered work and control the individual's work hours. Ceiling limits and break requirements always apply. A minimum of one day off in the preceding seven-day period is acceptable for individuals to begin or resume covered duties and for individuals who have been working an 8-hour shift schedule, as either day or shift workers, and are transitioning (1) from a non-covered group to a covered group or (2) from a covered group to another covered group that has more stringent MDO requirements. A minimum of two days off in the preceding seven-day period is acceptable for individuals who have been working a 10- or 12-hour shift schedule, as either day or shift workers, and transition (1) from a non-covered group to a covered group or (2) from a covered group to another covered group with more stringent MDO requirements. NRC edit NRC edit highlightedqppygg or planned security system outage. For unit outages, o. O n-NEI 06-11, Revision 2 April XXXXXX 20142016 40 A minimum of two days off in the preceding seven-day period is acceptable for operators at a multi-unit site with one or more units in an outage, if the operators have been working outage hours on 10- or 12-hour shifts before they transition to an operating unit as members of the minimum shift complement described in Section 6.1. There is no minimum day off requirement for transitioning from a non-covered to covered work if the individual has worked for the licensee for previous schedule was fewerless than seven days in length. See Section 20, Example 7. Unit Outage, Security System Outage

, or Increased Threat Condition Work Hour Controls - MDO Methodology NOTE: During a unit or planned security system outage, the options for control of work hours for covered workers are outage MDOs or staying with on-line work hour controls (MDO).

NOTE: If an individual is performing work under multiple categories, the most restrictive work hour controls apply

. During the first 60-day period of a unit or planned security system outage, the Covered Worker under outage rules will receive an average number of Days Off equal to or greater than the MDO requirement for the shift schedule that applies. Covered Individual** 8-hour shift Days off 10-hour shiftDays off 12-hour shiftDays off Actual Average Shift Hours 8 to less than or equal to 9 hours1.041667e-4 days 0.0025 hours 1.488095e-5 weeks 3.4245e-6 months Greater than 9 to less than or equal to 11 hours1.273148e-4 days 0.00306 hours 1.818783e-5 weeks 4.1855e-6 months Greater than 11 and less than or equal to 13 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Maintenance 1 day off per week 1 day off per week 1 day off per week Operations, HP, Chemistry, Fire Brigade 3 days off in each successive (i.e.,

non-rolling) 15-day period 3 days off in each successive (i.e.,

non-rolling) 15-day period Security 4 days off in each successive (i.e.,

non-rolling) 15-day period 4 days off in each successive (i.e.,

non-rolling) 15-day period **If the worker averages more hours than previously scheduled, the licensee must recalculate the average hours worked per shift to ensure the proper MDO (8, 10 or 12) is met prior to the end of the listed period. During the first 60-day period of an unplanned security system outage or increased threat condition, the requirements for MDOs for security personnel do not apply. NRC edit NRC edit NRC edit NEI 06-11, Revision 2 April XXXXXX 20142016 41 Extensions of 60-day period may be provided to individuals in seven-day increments for each non-overlapping seven-day period in which the individual has worked not more than 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months during the unit or security system outage or increased threat condition. The seven-day increments may only be used while the unit or security system is in outage.

This extension can be made any time in the outage period after the less-than-48-hour work week. This extension is calculated by a week defined as seven days. If every week of the initial 60 days is used for the extension only 56 days (eight weeks) are available for the extension. The 48-hour allowance can only be banked during the first 60 days of the outage and used no later than day 116 of the outage. See Section 20, Examples 13 and 14. 8.2.1 Unexpected Outages Unexpected outages can impact the licensee's ability to demonstrate compliance with the normal MDO requirements. During an outage, days off are required on a day basis every rolling seven-day period for personnel performing maintenance activities and every non-rolling 15-day period for all other covered workers for the duration of the outage and not on an average basis as when on-line. When entering an unexpected outage, the licensee shall be considered to be in compliance with the rule if the schedule for the shift cycle would have provided for the required minimum days off. 8.3 MAXIMUM AVERAGE WORK HOURS (MAWH) Maximum Average Work Hours (MAWH) Method The alternative approach to on-line MDO is a weekly maximum average of 54 hours6.25e-4 days 0.015 hours 8.928571e-5 weeks 2.0547e-5 months worked, based on a rolling averaging period of up to six weeks. This alternative is applicable to all covered workers, regardless of classification. The rolling periods used in the MAWH calculations roll by one full week at a time. The week may start on any specific day and must be consistent through the calculation period and documented in the controlling procedure. Rolling Period The averaging period starts "rolling" after a work history for a covered worker has been established equal to the length of the averaging period. The averaging period rolls by one full week at a time. The week does not have to start on any specific day but must be consistent through the calculation period and documented in the controlling procedure. NRC edit NEI 06-11, Revision 2 April XXXXXX 20142016 42 Shifts that bridge the point in time during the week when the averaging period rolls forward one week may be counted in one of two ways and the method must be documented in the controlling procedure: The hours for that shift may be included in the week the shift starts. The hours may be included in the weeks the hours are worked. Calculating the Average While the calculation of the average work hours worked occurs at the end of the averaging period, there is a need to be continually calculating the average looking forward to identify work hours that will potentially exceed the limit so that work hours can be adjusted or, as appropriate, waivers can be prepared in advance of exceeding the limit. One simple method is to add up the work hours from the previous five weeks and subtract from 324, giving the worker the maximum amount of hours that can be worked the upcoming week. Beginning a Rolling Averaging Period In the case of a worker who has not been performing on-line covered work and will be transitioning to on-line covered work, there are two options for setting up the schedule to start the averaging period: The schedule established for the worker for the initial averaging period (e.g., initial six weeks) can be set up as a fixed period which averages 54 hours6.25e-4 days 0.015 hours 8.928571e-5 weeks 2.0547e-5 months or less. The first week after this (e.g., seventh week worked) is the start of the rolling schedule. The number of weeks in the averaging period for the worker is determined and the hours for the past number of work weeks that is equal to the averaging period are calculated to establish the history needed to begin rolling. Partial Averaging Periods Partial averaging periods occur when a worker will not be working a full averaging period. If the individual is working for the licensee for less than a full week, then only ceiling limits and break requirements apply. If greater than one full week, but less than a full averaging period, then the licensee must limit the average work hours to 54 hours6.25e-4 days 0.015 hours 8.928571e-5 weeks 2.0547e-5 months per week or less averaged over the partial averaging period. Truncated Schedules If the fixed schedule is truncated due to unforeseeable events outside the control of the licensee, the worker will be considered to be in compliance with the rule if the schedule for the averaging period would have met the on-line averaging limit should the truncation not have occurred. Examples of unforeseeable events include:

NEI 06-11, Revision 2 April XXXXXX 20142016 43 Unexpected unit outage. A declared emergency as defined by the licensee's emergency plan. Duties of the worker are terminated. An unplanned security system outage (security only). An increased threat condition (security only). Following such an event, the licensee may start a new averaging period or choose not to truncate the averaging period. An extended absence is not considered an interruption or truncation of an averaging period but is considered part of the averaging period. Unit Outage, Security System Outage or Increased Threat Condition Work Hour Controls - MAWH Methodology During a unit or planned security system outage, the options for control of work hours for covered workers are outage MDOs (Section 8.2.4) or staying with MAWH work hour controls. In cases of an unexpected outage, which is anticipated to last only a short time, remaining on MAWH may be administratively beneficial.

8.4 OUTAGE SPECIFIC GUIDANCE - W ORK H OUR CALCULATIONS Detailed guidance for transitioning from on-line to outage and vice-versa is contained in Section 10, Transitions, and Table 10. Contract and Licensee Outage Workers Licensee employees and contractor/vendor personnel may go from an outage at one site to an outage at another site. When a licensee employee or contractor/vendor performs covered work for a licensee during two or more unit outages or security system outages (or a combination thereof), and the interval(s) between successive outages is less than 9 days, the receiving licensee should make a reasonable judgment as to the individual's fitness-for-duty relative to fatigue, for example, by conducting a fatigue assessment and ensuring that the individual has had a 34-hour break within the 9 days and will be in compliance with all work hour controls when resuming covered work. Licensees are not responsible for tracking individual's hours between outages for different licensees. No MDOs are required for individuals working for the licensee for a period of less than one week. If the Contractor does not have unescorted access, then the work performed is not covered. See Section 20, Example 1. Operator Relief at Multi-Unit Sites NRC edit NRC edit NEI 06-11, Revision 2 April XXXXXX 20142016 44 An operator who has been working outage work hours and has had two days off in the previous seven-day period may provide relief to the operator at the controls or the senior operator in the control room, if an appropriately qualified operator who has been working non-outage work hours is not immediately available to provide relief. If an operator who has been working outage work hours and has had two days off in the previous seven-day period is not immediately available, an operator who has been working outage hours may provide: Short-term relief (up to two hours) for the operator at the controls or the senior operator in the control room without a waiver. Longer-term relief (more than two hours) under a waiver of the MDO or MAWH requirement that is applicable to the shift schedule (i.e., 8-, 10-, or 12-hour shifts) for personnel assigned to the operating unit.

NEI 06-11, Revision 2 April XXXXXX 20142016 45 9 EXAMPLES OF APPLYING ALL WORK HOUR CONTROLS (26.205) 9.1 GENERAL W ORK HOUR REQUIREMENTS If a work hour limit will be exceeded, it shall be identified before the hours are worked. To determine if the minimum days off requirements will be met (before working the additional hours) a licensee may use one of the following methods: Calculate the minimum days off based on a backwards look of the previous five weeks and determine if the extra hours worked in the sixth week would still meet the requirement (rolling six-week cycle method). Ensure that sufficient days off still exist (within the shift cycle) to meet the minimum days off requirements (fixed shift cycle method).

Hours worked should be evaluated to determine if any limit will be exceeded based on the work schedule by picking a future time (T) on the work schedule and asking, "how many hours will have been worked during the T-24 hours, T-48 hours, or T-168 hours (T-7 calendar days)."

The limit for 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months in a seven-day period may be calculated using a rolling 168-hour window or based on seven calendar days (i.e., a backwards look at the number of hours that have or will have been worked based on a time in the future).

The period is not re-zeroed or the "clock reset" following a day off or after obtaining authorization to exceed the limits.

Licensees shall establish the accounting practices to be used in monitoring hours worked. In many cases this will parallel the established system for compensation. However, the accounting practices may be different from record keeping for payroll purposes. Work periods should be rounded consistently.

Work hour records should show the number of hours worked each calendar day. Work period start and stop times should be documented in a consistent manner. The level of precision in determining start and end times should not be greater than nominal 15 minute increments.

See Section 20, Examples 5-7, for clarifications.

NEI 06-11, Revision 2 April XXXXXX 20142016 46 TABLE 9A: W ORK HOUR CONTROLS - NORMAL OPERATIONS [See rule for details - table provides only a general summary of the rule] Sub- section Item Controls for Individuals Performing Duties Subject to Work Hour Controls Note 26.205(d)(1) Work hour limits Ensure that the individual's work hours do not exceed: 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months in any 24-hour period 26 hours3.009259e-4 days 0.00722 hours 4.298942e-5 weeks 9.893e-6 months in any 48-hour period 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months in any 7-day period Rolling limits 7-day period can be calculated as 168 hours0.00194 days 0.0467 hours 2.777778e-4 weeks 6.3924e-5 months or 7 calendar days 26.205(d)(2) Rest break requirements Ensure that the individual has at minimum: 10-hour break between successive work periods o May useAn 8-hour break between work periods is acceptable only when a break of less than 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months is necessary when needed to accommodate scheduled a crew's shift schedule transition and transition between work schedulesfrom a unit or security system outage or increased threat condition to operation 34-hour break in any 9-day period Rest break is the interval of time between successive work periods during which individual does not perform any duties for licensee Break time may include that portion of shift turnover that occurs outside the individual's scheduled work period 9-day period can be calculated as 216 hours0.0025 days 0.06 hours 3.571429e-4 weeks 8.2188e-5 months or 9 calendar days 26.205(d)(3) Minimum Days Off (MDO) If using the MDO method, ensure that the individual has at minimum the following days off per week averaged over shift cycle: 8-hour shift schedule: 1 day off/week average 10-hour shift schedule: 2 days off/week average 12-hour shift schedule: per week:

o 2.5 days off average for those performing duties listed in 26.4(a)(1)-(3) [Ops/HP-Chem/Fire brigade] o 2 days off average for those performing duties listed in 26.4(a)(4) [maintenance and quality inspections of maintenance

] o 3 days off average for those performing duties listed in 26.4 (a)(5) [securit y] Day off defined as a calendar day during which individual does not start a work period Duration of shift cycle may not exceed 6 weeks for purpose of calculating days off Shift cycle may not be less than 1 week [RG 5.73] Days off per week average is calculated as: (# days off in shift cycle) divided by(# weeks in shift cycle) NRC edit NEI 06-11, Revision 2 April XXXXXX 20142016 47 26.205(d)(7) Maximum Average Work Hours (MAWH) Alternative to MDOs If using the maximum average work hours (MAWH) method, ensure that individuals work no more than a weekly average of 54 hours6.25e-4 days 0.015 hours 8.928571e-5 weeks 2.0547e-5 months Averaged over period up to 6 weeks Averaging period advances by 7 consecutive calendar days at finish of every averaging period For shifts that span 2 calendar days, either:

Count all hours worked as if they were worked on the day the shift started, or Count hours on calendar days they were actually worked 26.205(d)(8) State Alternative Used Clearly state in the FFD policy and procedureswhich requirements are being applied during both operations and outages: MDO or MAWH requirements

NEI 06-11, Revision 2 April XXXXXX 20142016 48 TABLE 9B: W ORK H OUR CONTROLS - UNIT OUTAGES , SECURITY SYSTEM OUTAGES, AND INCREASED THREAT CONDITIONS

[See rule for details - table provides only a general summary of the rule] Sub- section Item Controls for Individuals Performing Duties Subject to Work Hour Controls Note 26.205(d)(1) Individual work hours Ensure that the individual's work hours do not exceed: 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months in any 24-hour period 26 hours3.009259e-4 days 0.00722 hours 4.298942e-5 weeks 9.893e-6 months in any 48-hour period 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months in any 7-day period Rolling limits 7-day period can be calculated as 168 hours0.00194 days 0.0467 hours 2.777778e-4 weeks 6.3924e-5 months or 7 calendar days 26.205(d)(2) Rest break requirements Ensure that the individual has at minimum:

10-hour break between successive work periods May use 8-hour break between work periods when break of less than 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months is needed to accommodate a crew's shift schedule transition from a unit or security system outage or increased threat conditionoutage to operation. 34-hour break in any 9-day period A rest break is the interval of time between successive work periods during which the individual does not perform any duties for licensee Break time may include that portion of shift turnover that occurs outside the individual's scheduled work periodshift turnover 9-day period may be calculated as 216 hours0.0025 days 0.06 hours 3.571429e-4 weeks 8.2188e-5 months or 9 calendar days 26.205(d)(4) Unit outage - minimum days off - Operations, HP/Chem/Fire brigade If using the MDO method, ensure that the individuals working on outage activities and performing duties listed in 26.4(a)(1)-(3) [operations, HP/chem., fire brigade] have at minimum the following days off:

3 days off each successive 15-day period Requirement applies for the first 60 days of a unit outage Requirement applies to successive 15-day periods (i.e., non-rolling)

Applies only to individuals working on outage activities 26.205(d)(4) Unit outage - minimum days off - maintenance and quality inspections of maintenance If using the MDO method, ensure that the individuals working on outage activities and performing duties listed in 26.4(a)(4) [maintenance and quality inspections of maintenance] have at minimum the following days off:

1 day off in any 7-day period Requirement applies for the first 60 days of a unit outage Requirement applies to rolling 7-day periods Applies only to individuals working on outage activities NRC edit NRC edit NEI 06-11, Revision 2 April XXXXXX 20142016 49 26.205(d)(5) Unit outage, security system outage, or increased treat condition - minimum days off - security If using the MDO method, ensure that the individuals performing duties listed in 26.4(a)(5) [security] have at minimum the following days off:

For unit outage (planned or unplanned) or for planned security system outage: 4 days off each successive 15-day period For unplanned security system outage or increased threat condition: no minimum days off are required Requirement applies for the first 60 days of a unit outage, security system outage, or increased threat condition Requirement applies to successive 15-day periods (i.e., non-rolling)

Applies only to individuals working on outage activities 26.205(d)(6) Extension of outage/threat condition requirements If using the MDO method, the outage/increased threat MDO requirements may be extended on an individual basis in 7-day increments beyond the 60-day limit For each non-overlapping 7-day period during an outage or increased threat condition in which the individual did not work more than 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months Applies only to individuals working on outage activities 26.205(d)(7)

Alternate method of control of work hours Licensees may, as an alternative to complying with the minimum days off requirements in § 26.205(d)(3), comply with the requirements for maximum average work hours Licensee may elect to remain on MAWH during an outage vice Outage

MDO For short-term outages it may be administratively beneficial 26.205(d)(8) FFD program requirements Each licensee shall state, in its FFD policy and procedures required by § 26.27 and

§ § 26.203(a) and (b), the requirements with which the licensee is complying: the minimum days off requirements in

§ § 26.205(d)(3) or maximum average work hours requirements in § 26.205(d)(7) Licensee may not allow one work group to apply MDO and another to apply MAWH The site must apply the selected method of compliance to all work groups NRC edit NEI 06-11, Revision 2 April XXXXXX 20142016 50 TABLE 9C: APPLYING EACH CONTROL - W ORK HOUR LIMITS AND REST BREAK REQUIREMENTS Topic 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months in 24 26 hours3.009259e-4 days 0.00722 hours 4.298942e-5 weeks 9.893e-6 months in 48 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months in 7 days/168 hours 10-hour rest break 34-- rest break in 9- day/216-hr Limit applies to:

All covered workers All covered workers All covered workers All covered workers All covered workers When limits apply:

At all times individual is performing covered work for the licensee At all times individual is performing covered work for the licensee At all times individual is performing covered work for the licensee Before the start of a work period in which the individual is performing covered work for the licensee At all times an individual is performing covered work for the licensee Work hour limits and break requirements 16 work hours 26 work hours 72 work hours 10 hour1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months rest break (continuous 10 hour1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months break) 34 hour3.935185e-4 days 0.00944 hours 5.621693e-5 weeks 1.2937e-5 months rest break (continuous 34 hour3.935185e-4 days 0.00944 hours 5.621693e-5 weeks 1.2937e-5 months break) Allowed deviations None None None An 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months rest break is allowed when needed to accommodate a crew's shift schedule transition from unit outage, security system outage , or increased threat condition to operation. None Apply hours worked to: 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months 7 days or 168 hours0.00194 days 0.0467 hours 2.777778e-4 weeks 6.3924e-5 months The time between the end of one work period and the start of the next work period 9 days or 216 hours0.0025 days 0.06 hours 3.571429e-4 weeks 8.2188e-5 months Calculation period Rolling Rolling Rolling Sequential RollingNRC edit NEI 06-11, Revision 2 April XXXXXX 20142016 51 Topic 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months in 24 26 hours3.009259e-4 days 0.00722 hours 4.298942e-5 weeks 9.893e-6 months in 48 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months in 7 days/168 hours 10-hour rest break 34-- rest break in 9- day/216-hr Calculation Period The calculation period has no designated starting or ending time relative to the calendar or clock. It continues through work hours and breaks and ends 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after it starts For individuals starting or resuming covered work, the 24-hour calculation period begins 24hours before the start of covered work The calculation period has no designated starting or ending time relative to the calendar or clock but continues through work hours and breaks and ends 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months after it starts For individuals starting or resuming covered work, the calculation period begins 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months before the start of covered work If using a 7-day period, the calculation period starts at 12 am of a calendar day, and ends at 11:59 p.m. 7 calendar days later If using 168-hour period, the calculation period has no designated starting or ending time relative to the calendar or clock. It continues through work hours and breaks and ends 168 hours0.00194 days 0.0467 hours 2.777778e-4 weeks 6.3924e-5 months after it starts For individuals starting or resuming covered work, the calculation period begins 7 days or 168 hours0.00194 days 0.0467 hours 2.777778e-4 weeks 6.3924e-5 months before the start of covered work The calculation period begins at the end of one work period and ends at the start of the next (subsequent) work period For individuals starting or resuming work the calculation period begins at the end of the previous work period If using a 9-day period, the calculation period starts at 12am of a calendar day, and ends at 11:59 pm 9 days later. If using a 216 hour0.0025 days 0.06 hours 3.571429e-4 weeks 8.2188e-5 months period the calculation has no designated starting or ending time relative to the calendar or clock. It continues through work hours and breaks and ends 216 hours0.0025 days 0.06 hours 3.571429e-4 weeks 8.2188e-5 months after it starts.

For individuals starting or resuming covered work, the calculation period begins 9 days or 216 hours0.0025 days 0.06 hours 3.571429e-4 weeks 8.2188e-5 months before the start of covered work. By what increments does the calculation period move? It rolls in hour-by- hour increments It rolls in hour-by-hour increments If using 7-day period, it rolls in day-by-day increments If using 168-hour period, it rolls in hour-by-hour increments It moves sequentially from break period to break period. - If using 9-day period, it rolls in day-by-day increments

- If using 216-hour period, it rolls in hour-by-hour increments

NEI 06-11, Revision 2 April XXXXXX 20142016 52 TABLE 9D: APPLYING EACH CONTROL - MDO AND MAWH REQUIREMENTS Information needed to apply either MDO or the MAWH requirements Topic MDO - Normal Operations MDO - Outag e Conditions - Ops, HP/Chem, Fire Brigade MDO - Outag e Conditions

- Maintenanc e and Quality Inspection s MDO - Outag e Conditions - Sec u rity MAWH 54-hr Alternative To whom does it apply?

All covered workers To determine specific number days off required, determine both individual's duties as well as applicable shift schedule (based on average hours worked per day over shift cycle) All covered workers performing duties listed in 26.4(a)(1)-(3) All covered workers performing duties listed in 26.4(a)(4) All covered workers performing duties listed in 26.4(a)(5) All covered workers, irrespective of duties or shift schedule When does it apply? At all times the individual is performing covered work for the licensee during normal operations At all times the individual is performing covered work for the licensee under outage conditions; some exceptions for operators at multi-unit sites At all times the individual is performing covered work for the licensee under outage conditions At all times the individual is performing covered work for the licensee under outage conditions At all times the individual is performing covered work forthe licensee NEI 06-11, Revision 2 April XXXXXX 20142016 53 Topic MDO - Normal Operations MDO - Outag e Conditions - Ops, HP/Chem, Fire Brigade MDO - Outag e Conditions

- Maintenanc e and Quality Inspection s MDO - Outag e Conditions - Sec u rity MAWH 54-hr Alternative What is the limit or value to track? Days off (defined as a calendar day during which individual does not start a work shift), as follows: 8-hour shift schedule: 1 day off/week average 10-hour shift schedule: 2 days off/week average 12-hour shift schedule: per week:

o 2.5 days off average for those performing duties listed in 26.4(a)(1)- (3) [OPS/HP/Chem/ Fire brigade]

o 2 days off average for those performing duties listed in 26.4(a)(4) [maintenance]

o 3 days off average for those performing duties listed in 26.4(a)(5) [security] 3 days off (defined as a calendar day during which individual does not start a work shift) in each successive 15-day period 1 day off (defined as a calendar day during which individual does not start a work shift) in any 7-day period 4 days off (defined as a calendar day during which individual does not start a work shift) in each successive 15-day period for unit outages (planned or unplanned) or for planned security system outages Average may not exceed 54 work hours per week over the rolling averaging period.

NEI 06-11, Revision 2 April XXXXXX 20142016 54 Topic MDO - Normal Operations MDO - Outag e Conditions - Ops, HP/Chem, Fire Brigade MDO - Outag e Conditions

- Maintenanc e and Quality Inspection s MDO - Outag e Conditions - Sec u rity MAWH 54-hr Alternative Specific exceptions to the limit or value of this requirement [Note-this is an exception to the limit or value of the control, not the exceptions to the calculation of work hours specified in 26.205(b) and 26.20(d)(7)II)] No MDOs are required for individuals working for the licensee for a period of less than one week If a shift cycle during normal operations is cut short due to the unit transitioning into an outage or increased threat condition, MDO requirements are considered met if an individual's scheduled days off during the truncated period would have provided the required days off for the shift cycle To accommodate a change in shift schedules, the licensee may end a shift cycle and start a new one.

MDO requirements and compliance of individuals working the shortened shift No MDOs are required for individuals working for the licensee for a period of less than one week Some exceptions for operators at multi-unit sites The 60-day period during which these MDO requirements apply may be extended for each individual in 7-day increments for each non-overlapping 7-day period the individual has worked not more than 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months during the outage No MDOs are required for individuals working for the licensee for a period of less than one week.

The 60-day period during which these MDO requirements apply may be extended for each individual in 7-day increments for each non-overlapping 7-dayperiod the individual has worked not more than 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months during the outage No MDOs are required for individuals working for the licensee for a period of less than one week.

During the first 60 days of an unplanned security system outage or increased threat condition: no minimum days off are required (security personnel only)

The 60-day period during which these MDO requirements apply may be extended for each individual in 7-day increments for each non- overlapping 7-day period the individual has worked not more than 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months during the outage During the first 60 days of an unplanned security system outage or increased threat condition: the maximum average work hour limits need not be met. Cycle may be determined by looking back a period that is equal in length to the shift cycle the individual was working before the change (e.g., the past 6 weeks)

NEI 06-11, Revision 2 April XXXXXX 20142016 55 Topic MDO - Normal Operations MDO - Outag e Conditions - Ops, HP/Chem, Fire Brigade MDO - Outag e Conditions

- Maintenanc e and Quality Inspection s MDO - Outag e Conditions - Sec u rity MAWH 54-hr Alternative What is its calculation period? Shift cycle, which is set by the licensee, cannot be less than one week nor exceed 6 weeks, but can vary within these limits 15-day period 7-day period 15-day period Averaging period, which cannot exceed 6 weeks, and is defined in days How does the calculation period move? Sequential Sequential Rolling Sequential Rolling What/when is the beginning and end of the calculation period? The calculation period starts at the beginning of the shift cycle and ends at the end of the shift cycle; days off per week average is calculated as: (# days off in shift cycle) divided by (# weeks in shift cycle) The calculation period starts at the beginning of each 15-day period and ends at the end of the 15-day period The calculation period starts at the beginning of each 7-day period and ends at the end of the 7-day period The calculation period starts at the beginning of each 15-day period and ends at the end of the 15- day period The calculation period starts on the first day of averaging period and ends on the last day of the averaging period. Licensee must specify the time of day the averaging period starts and stops. Note that for shifts that span 2 calendar days, licensee can either: Count all hours worked as if they were worked on the day the shift started, or Count hours on calendar days they were actually worked By what increments does the calculation period move? By shift cycle By 15-day period Day-by-day By 15-day period By 7 consecutive calendar days (i.e., rolling weeks)

NEI 06-11, Revision 2 April XXXXXX 20142016 56 10 TRANSITIONS 10.1 T YPES OF TRANSITIONS NOTE: Maintain compliance through transitions. Transitions Between On-Line Schedules Licensees may transition individuals or crews between shift schedules by ending a shift cycle and starting a new shift cycle with a different shift schedule. The following guidance applies: Terminating the shift cycles:

o Ensure that the individuals meet the MDO requirement applicable to the shift schedule that the individuals were working before it was terminated.

o In these instances, for the purpose of determining compliance with the MDO requirements, the licensee may average the individuals' work hours over a period immediately preceding the transition that is equal in length to the shift cycle the individuals were working before the transition (e.g., six weeks, if the shift cycle was six weeks in length). The licensee should then ensure that the individual meets the applicable MDO requirement for the new shift schedule going forward from the beginning of the new shift cycle. A shift cycle may be as short as one week. There are no MDO requirements for individuals working for the licensee for periods of fewerless than seven days. Transitions Between On-Line and Outage Schedules The ceiling and break requirements apply at all times when transitioning between outage and on-line schedules. The outage MDOs only apply while in a unit outage or planned security system outage. For unit outages, o. On-line work hour controls (MDO or MAWH) take effect the first shift after the reactor unit achieves 75 percent reactor power or until seven calendar days have elapsed since reconnecting reconnects the reactor unit to the electrical grid whichever is shorter. For the first 42 days after an outage (for six-week cycles) the employee must be evaluated using the fixed-shift cycle method. Transitions Between Covered Groups or Onto a Covered Shift If an individual begins or resumes performing for the licensee any covered work during the calculation period, the licensee shall include in the calculation of the individual's work hours all work hours worked for the licensee, including hours worked performing duties that are not covered work and control the individual's work hours. A minimum of one day off in the preceding seven-day period is acceptable for individuals to begin or resume covered duties and for individuals who have been working an eight-hour shift schedule, as either day or shift workers and are transitioning from a non-covered group to a covered group or from a covered group to another covered group that has more stringent MDO requirements. Commented [A9]: Please add guidance here re: planned security system outages for security personnel.

NRC edit NRC edit gg or planned security system goutage. For unit outages, o. O For n NEI 06-11, Revision 2 April XXXXXX 20142016 57 A minimum of two days off in the preceding seven-day period is acceptable for individuals who have been working a 10- or 12-hour shift schedule, as either day or shift workers, and transition from a non-covered group to a covered group or from a covered group to another covered group with more stringent MDO requirements.

A minimum of two days off in the preceding seven-day period is acceptable for operators at a multiunit site with one or more units in an outage, if the operators have been working outage hours on 10- or 12-hour shifts before they transition to an operating unit as members of the minimum shift complement described in Section 6.1. No MDOs are required for individuals working for the licensee for a period of less than one week See Section 20, Example 7.

NOTE: Ceiling limits and break requirements apply under all circumstances unless waived or specifically exempted in Section 7. NOTE: During a unit or planned security system outage, the options for control of work hours for covered workers are outage MDOs or staying with on line work hours controls.

NOTE: If an individual is performing work under multiple categories, the most restrictive work hour controls apply. Transitioning to a Planned Outage Using the MDO Method Rolling shift cycles: Since the rolling evaluation method is a backwards look at days worked, online MDOs are in compliance when entering a planned outage. Fixed shift cycles: The working hours must be carefully managed working towards the beginning of an outage. In the last week prior to the outage, the number of days off must meet the on-line MDO requirement for the applicable shift schedule. These individual may either need additional days off or have their working hours adjusted to meet the required MDOs for a fixed evaluation period prior to entering the planned outage. Schedules can also be abbreviated to less than a full shift cycle, even if this results in in a shift cycle that contains partial weeks. In these cases the required number of MDOs is prorated over the abbreviated schedule. For example, 30 days is 4.3 weeks. A 12-hour shift operator shift would require 4.3 x 2.5 MDO/week or 11 days off during the 30 days to be in compliance with the rule. Transitioning From a Planned Outage to On-Line Using the MDO Method Return to on-line work hour limitations starts a new shift cycle. As long as the worker has not exceeded the maximum number of allowed work days for the final calculation period of the outage (seven-day rolling or 15-day fixed), the licensee shall be considered to be in compliance with the rule. NRC edit NEI 06-11, Revision 2 April XXXXXX 20142016 58 Transitioning to a Planned Outage Remaining in the MAWH Method No additional guidance needed. Transitioning from a Planned Outage to On-Line Using the MAWH Method See Table 10 for guidance on transitioning out of an outage.

NEI 06-11, Revision 2 April XXXXXX 20142016 59 TABLE 10: TRANSITIONS OUT OF AN OUTAGE Control Outage On-Line OperationsNo more than 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months worked in 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Must remain in compliance through outageLook back and roll forward without interruption-no difference across transition No more than 26 hours3.009259e-4 days 0.00722 hours 4.298942e-5 weeks 9.893e-6 months worked in 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months Must remain in compliance through outageLook back and roll forward without interruption-no difference across transition No more than 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months worked in 7-days/168 hours Must remain in compliance through outageLook back and roll forward without interruption-no difference across transition 10 hour1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months break between successive work periods Must remain in compliance through outageLook back and then move forward to next break without interruption- no difference across transition 34 hours3.935185e-4 days 0.00944 hours 5.621693e-5 weeks 1.2937e-5 months break in any 9- day period Must remain in compliance through outageLook back and roll forward without interruption-no difference across transition Minimum Days Off (MDO) to MDO Must be in compliance with outage requirements throughout and at time of transition out of outage New shift cycle starts at point of transition; no look back MDO during outage to Maximum Average Work Hour (MAWH) requirements during normal operations Must be in compliance with outage requirements throughout and at time of transition out of outage Establish fixed initial averaging period after the transition, then roll forward in seven-day increments and continue to roll forward by seven-day increments If a partial week occurs, the hours worked during the partial week are not included in the MAWH calculation averaging period MAWH during outage to MAWH during normal operations Must remain in compliance through outageNo difference across transition, continue to roll forward by seven-day increments, maintaining compliance throughout

NEI 06-11, Revision 2 April XXXXXX 20142016 60 11 WAIVERS (26.207)

11.1 INTRODUCTION

There will be unforeseen circumstances that may require issuance of a waiver. The issuance of a waiver is expected to meet a high threshold and be infrequent. Waivers are only applicable to covered workers and should not be considered a routine methodology to circumvent work hour controls. The annual assessment evaluates the use of waivers and requires a determination of adequate staffing if multiple waivers are issued through the year. Tables 13A and 13B are provided for reference.

11.2 APPLICABILITY A waiver is only permitted when necessary to mitigate or prevent a condition adverse to safety, or to maintain site security. Waivers can be issued for the work hour controls of break requirements, ceiling limits, minimum days off and the maximum average work hours limit as applicable. Each limit requires a distinct and separate waiver, although they can be processed together on one form at the discretion of the licensee's program. To the extent practicable, licensees shall rely upon the granting of waivers only to address circumstances that could not have been reasonably controlled. If the covered work authorized under a waiver is completed prior to the expected time, the specific worker under the waiver should be sent home for a required break period to reset his/her work hours/schedule.

11.3 WAIVER P ROCESS The process for granting waivers includes the following distinct steps: Licensee identifies need and describes basis for waiver. Either:

o Operations shift manager determines a waiver is necessary to mitigate or prevent a condition adverse to nuclear safety.

o A security shift manager determines that the waiver is necessary to maintain site security.

o A site senior-level manager with requisite signature authority makes either determination.

o Name of the individual for which a waiver is requested.

o Date and time the request is initiated.

NEI 06-11, Revision 2 April XXXXXX 20142016 61 o Work hour controls/limits for which a waiver is required.

o Date and time waiver will start.

o Duration of the waiver. For example, how many hours worker will exceed the work hour controls?

o Description of the work to be performed. This should be in adequate detail to support the face-to-face supervisory assessment of fitness for a waiver.

o Circumstances that caused the job extension. Review and approval by the operations shift manager or security shift manager as appropriate.

o Basis for approval.

o Name, signature, date and time. Supervisory Assessment of Fitness for a Waiver NOTE: The Supervisory Assessment of Fitness for a Waiver shall be completed before the start of a waiver period and no more than 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months prior to the beginning of work under a waiver. Review the work history for the past 14 days as reported by the individual for whom the waiver is requested and determine if the individual has worked for a licensee who is subject to Subpart I of Part 26 over the past 14 days, as documented by that licensee. A statement of how the following were considered: Potential for acute fatigue-time since last 10-hour break. Potential for cumulative fatigue-review work history above. Circadian factors-time of day and recent work cycle. Observation and statements of the individual. How fatigue could affect the work quality, if at all. Nature of work to be performed. Are controls and conditions on work required? If yes, describe. Name, signature, date, and time review supervisory assessment completed by supervisor. Waiver Closeout In many cases, waivers are generated as a contingency for a job and not used. The information in this section is to support the periodic reviews that are required. Hours actually worked, beyond the work hour limits, under this waiver. Did the individual perform satisfactorily? Job supervisor's name, signature and date close out waiver review.

NEI 06-11, Revision 2 April XXXXXX 20142016 62 Granting Waivers In order to grant a waiver, the licensee shall meet the following requirements: Shift Manager or Security Shift Manager Approval: An operations shift manager determines that the waiver is necessary to mitigate or prevent a condition adverse to safety, or a security shift manager determines that the waiver is necessary to maintain site security, or a site senior-level manager with requisite signature authority makes either determination. Supervisory Assessment of Fitness for a Waiver:

o A supervisor assesses the individual face to face and determines that there is reasonable assurance that the individual will be able to safely and competently perform his or her duties during the additional work period for which the waiver will be granted.

o The supervisor performing the assessment shall be trained in accordance with the requirements of §§ 26.29 and 26.203(c) and shall be qualified to direct the work to be performed by the individual.

o If there is no supervisor on site who is qualified to direct the work, the supervisory assessment may be performed by a supervisor who is qualified to provide oversight of the work to be performed by the individual. The supervisor, if knowledgeable of the work activity, can be a second level supervisor or a manager in the chain of command.

NOTE: Supervisory Assessments of Fitness for Waivers differ from Fatigue Assessments. For a comparison, Refer to Table 13B in Section 13, Fatigue Assessments.

11.4 SUPERVISORY A SSESSMENT FOR WAIVER OF R EGULATORY WORK HOURS C ONTROLS A Supervisory Assessment of Fitness for a Waiver is required to evaluate the capability of an individual to safely and competently perform covered work during any work period or shift when a waiver is being used to allow the work hour limits (10 CFR 26.205) to be exceeded. Although a waiver applies to an operational plant condition or to maintain site security and may involve multiple individuals over multiple shifts, the supervisory assessment of fitness applies to an individual and is valid for one work period or shift for that individual. A separate supervisory assessment of fitness for a waiver must be conducted for each individual working under the waiver and for each work period. The face-to-face portion of the supervisory assessment of fitness for a waiver must be performed within a four-hour window prior to commencing work under the waiver and must support a reasonable conclusion regarding the potential for worker fatigue during the work period or shift covered by the supervisory waiver assessment.

NEI 06-11, Revision 2 April XXXXXX 20142016 63 At a minimum, the supervisory waiver assessment must address the potential for acute and cumulative fatigue during the period covered by the waiver, considering the individual's work history for at least the past 14 days, the potential for circadian degradations in alertness and performance considering the time of day for which the waiver will be granted, the potential for fatigue-related degradations in alertness and performance to affect risk-significant functions, and whether any controls and conditions must be established under which the individual will be permitted to perform work. This is both a real time assessment and predictive assessment of potential for fatigue. The licensee should consider and establish additional fatigue counter-measures to further mitigate the potential for fatigue during the work period or shift. A new supervisory assessment of fitness is required prior to each subsequent work period or shift that the affected individual performs covered work in excess of the work hour limits as allowed by an approved waiver. The individual's obligation and rights to self-declare fatigue remain in effect while working under a waiver. The supervisor performing the supervisory assessment of fitness for a waiver must be qualified to direct the work being performed under the waiver. If the job supervisor is not on site, a supervisor qualified to perform oversight of the work being performed must conduct the supervisory assessment of the individual to work under a waiver.

11.5 S EQUESTRATION Personnel may be sequestered prior to and during significant adverse weather (e.g., hurricane, major snow storm, etc.). Waivers may be used to meet minimum staff positions. Waivers are not required to meet the The break requirements for personnel sequestered can be met on site provided they individuals are assigned no duties during the break and they are afforded the opportunity, as well as reasonable accommodations, to obtain restorative sleep. Reasonable accommodations would include a sleep surface (e.g., bed, recliner, etc.) in a darkened, quiet room. Licensees need not meet the requirements of 10CFR 26.205 (c) and (d) for up to 96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months when acts of nature or a disaster is declared. An act of nature or a disaster would be defined by an active warning from an independent government agency indicating that access to the licensee's site may be restricted or individual travel to the site may be hazardous. NRC edit highlighted d they individuals they a p rovided they are assigned no duties during the break and they are afforded the opportunity, as well as reasonable accommodations, to obtain restorative sleep. Reasonable accommodations

would include a sleep surface (e.g., bed, recliner, etc.) in a darkened, quiet room.

NEI 06-11, Revision 2 April XXXXXX 20142016 64 This exception expires when the licensee can adequately staff the site within the provisions of 26.205 (c) and (d) within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months or the beginning of the next normally scheduled shift rotation, whichever is greater, 3 from the time when the active warning is canceled.

3 The 6-hours post-warning cancellation will provide enough time for relief staff to access the site or for the appropriate supervisory assessments to be performed for waivers. Six hours would provide the ability for restorative sleep for relieving workers. Providing additional flexibility to extend the provision of 26.207 (e) allows an orderly transition to normal covered work schedules.

NEI 06-11, Revision 2 April XXXXXX 20142016 65 TABLE 11A: W AIVER PROCESS [See rule for details - table provides only a general summary of the rule] Sub-section Waiver Requirement Note 26.207(a) Licensee may grant a waiver to any work hour controls listed in Section26.205(d)(1) through (d)(5)(i) and 205(d)(7) In cases where more than one work hour control is affected, each control must be waived explicitly 26.207(a)(1)(i) To grant waiver, a determination must be made that the waiver is necessary to mitigate or prevent a condition adverse to safety or necessary to maintain site security The determination must be made by either: an operations shift manager, for conditions adverse to safety a security shift manager, for conditions necessary to maintain site security a site senior-level manager with requisite signature authority, for either condition 26.207(a)(1)(ii) To grant waiver, a determination must be made that there is reasonable assurance the individual will be able to safely and competently perform his/her duties during the additional work period under waiver The determination must be made by a supervisor assessing the individual face to face.

The supervisor must be both: trained under Section 26.29 and Section 26.203(c) qualified to direct the work, or if none available on site, then one qualified to provide oversight of the work The assessment must address at minimum: potential for acute and cumulative fatigue, considering work history for at least past 14 days potential for circadian degradations in alertness and performance considering time of day potential for fatigue to affect risk-significant functions whether controls or conditions must be established 26.207(a)(2) To extent practicable, waivers should be used only to address circumstances that could not have been reasonably controlled Waiver is not intended for use to address inadequate staffing or work planning, or other circumstances a licensee could reasonably foresee (see FRN, March 31, 2008, p.17147) 26.207(a)(3) Timing of face-to-face supervisory assessment must support a valid assessment of potential for worker fatigue during period of time covered by waiver In all cases, the face-to-face assessment may not be performed more than 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months before beginning work under the waiver NEI 06-11, Revision 2 April XXXXXX 20142016 66 26.203(d)(3) and 26.207(a)(4) Licensees must document individual waivers granted Each work hour control that is waived must be documented The documentation must describe the basis for the waiver, including: a description of circumstances requiring the waiver a statement of the scope of work and time period for which waiver approved the bases for the determinations in 26.207(a)(1)(i) and (ii) 26.203(e)(1) and 26.203(e)(2) Include summaries of waivers granted and corrective actions taken in the Annual FFD Program Performance Report (26.717) Provide a summary report of waivers from the previous calendar year for each nuclear power plant, as well as a summary report of corrective actions, if any, resulting from the analyses of waiver data

NEI 06-11, Revision 2 April XXXXXX 20142016 67 TABLE 11B: W AIVERS AND EXCEPTIONS TO W ORK H OUR C ONTROLS [See rule for details - table provides only a general summary of the rule] Sub-section Type of Waiver or Exception Relevant to Which Individuals Requirements Affected Implementation Details 26.207(a) Licensee waiver of work hour controls All individuals subject to work hour controls 26.205(d)(1) through (d)(5)(i) - work hour control requirements Waiver of requirements: Continue to count/calculate work hours; requirements are waived for specific limits as detailed in waiver 26.207(b) NRC-evaluated force-on-force tactical exercises exception All security personnel (not just those taking part in exercise) 26.205(d)(3) - Minimum days off 26.207(d)(7) Maximum Average Work Hours Affects work hour calculation: May exclude shifts worked during the actual conduct of these exercises when calculating individual's number days off (as per MDO requirements, or when calculating weekly average hours worked (as per the MAWH requirements)

the exclusion does not apply to security personnel providing security for the facility during the exercise 26.207(c) Common defense and security exception All security personnel 26.205, or any specified subset thereof - i.e., work hour scheduling and control requirements Exception to work hour controls: When informed in writing by NRC, specified requirements need not be met for the duration of the period defined by NRC** NRC edit NEI 06-11, Revision 2 April XXXXXX 20142016 68 26.207(d) Plant emergency exception All individuals subject to work hour controls 26.205(c) and (d) - work hour scheduling and work hour controlsMay exclude from the calculation unscheduled work hours for the purposes of responding to a declared plant emergency, as defined in the licensee's emergency plan. **

26.205(b)(4) Unannounced emergency preparedness exercises or drills Individuals participating in actual conduct of exercises or drill 26.205(d) - work hour control requirements Affects work hour calculation: Unscheduled work hours performed while participating in the actual conduct of exercises or drills may be excluded from work

hour counts/calculations

- All scheduled hours worked are still accounted for and entered into the software.

NEI 06-11, Revision 2 April XXXXXX 20142016 69 12 SELF DECLARATIONS (26.209) 12.1 APPLICABILITY AND G ENERAL PROVISION It is the individual's responsibility to make a clear self-declaration of fatigue. Site procedures should clearly identify how a self-declaration will be made and leave no room for confusion. A casual statement to a supervisor or fellow employee that an individual is tired is not a self-declaration. The process shall leave no confusion that a declaration was made and when it was made. It should also be clear that a fatigue assessment is not needed if the supervisor agrees with the individual and provides a rest break of at least 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months . Any on-site individual covered by the FFD program can self-declare whether or not they are performing covered work. See Section 15.4 (b) Table 12 for Self-Declaration follow-up requirements.

12.2 S ELF-DECLARATIONS DURING EXTENDED WORK HOURS UNDER WAIVER If an individual is performing, or being assessed for, work under a waiver of the work hour controls and declares that, due to fatigue, he or she is unable to safely and competently perform his or her duties, the licensee shall immediately stop the individual from performing any covered work. The exception to this is if the individual is required to continue performing those duties under other requirements of the regulations, e.g., meet minimum licensed operator staffing. If the subject individual must continue performing the covered work until relieved, the licensee shall immediately take action to relieve the individual. Following the self-declaration or relief from performing covered work, as applicable, the licensee: May reassign the individual to duties other than covered work, but only if the results of a fatigue assessment indicate that the individual is fit to safely and competently perform those other duties. Shall permit or require the individual to take a break of at least 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months before the individual returns to performing any covered work.

NEI 06-11, Revision 2 April XXXXXX 20142016 70 TABLE 12: S ELF-DECLARATION PROCESS [See rule for details - table provides only a general summary of the rule] Sub-section Self-declaration Requirement Note 26.203(b)(1) Establish written procedure to follow when an individual makes a self-declaration that he/she is not fit to safely and competently perform duties for any part of a work period as a result of fatigue, including: Individual's rights and responsibilities Requirements for controls and conditions Process to follow if individual disagrees with results of fatigue assessment Applies to all individuals who have unescorted access to nuclear power plant protected areas-not just the categories of workers who are subject to work hour controls Self-declaration must be formalized, not a simple statement of being "tired" 26.209(a) Take immediate action in case of a self- declaration while the individual is performing or being assessed for work under a waiver: Immediately stop individual from performing duties listed in Section 26.4(a) Exception: If individual is required to perform covered duties, based on other requirements of Title 10 CFR, then immediately take action to relieve individual Applies only to self-declaration by individuals performing covered work under a waiver, or being considered for work under a waiver 26.211(a)(2) Conduct a fatigue assessment Exception: If the individual is required or permitted to take a rest break of at least 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months , then a fatigue assessment is not required Required in response to self-declaration to supervisor that individual is not fit to safely and competently perform duties for any part of a work period because of fatigue 26.209(b) Subsequent to self-declaration: Individual may be reassigned to duties other than those listed in Section 26.4(a) if results of fatigue assessment indicate individual can safety and competently perform those other duties Individual must be permitted or required to take a break of at least 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months prior to returning to covered work Applies only to self-declaration by individuals performing covered work under a waiver or being considered for work under a waiver 26.211(a)(4) Conduct follow-up fatigue assessment in cases when individual is returned to performing any duties following a break of less than 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months Individual must be reassessed for fatigue and the need for controls and conditions must be determined before the individual can resume duties NEI 06-11, Revision 2 April XXXXXX 20142016 71 13 FATIGUE ASSESSMENTS (26.211)

13.1 INTRODUCTION

A fatigue assessment is an evaluation of an individual by an authorized trained fatigue assessor to make a determination regarding that individual's ability to perform any assigned duties within the scope of the fitness-for-duty program with respect to fatigue. Fatigue assessments while similar to supervisory assessments of fitness for waivers, have distinct attributes including when they will be performed, what qualifications are needed to perform a fatigue assessment and the requirements to not have a conflict of interest. Additional information is provided in Tables 13A and B. 13.2 CONDITIONS REQUIRING FATIGUE ASSESSMENT There are four conditions under which a fatigue assessment is required for all personnel under general requirements of the fitness-for-duty program: For-cause. Self-declaration. Post-event. Follow-up. For-Cause A for-cause fatigue assessment is initiated by a supervisor based on direct behavioral observation or based on credible information provided by others. Observation for fatigue should not be applicable during an individual's break period. The fatigue assessor may not be the individual who observed the condition of impaired alertness. The drug and alcohol testing requirements of the FFD program may also apply in a for-cause situation. If the observed condition is impaired alertness with no other behaviors or physical conditions creating a reasonable suspicion of possible substance abuse, then the drug/alcohol testing is not required. If the affected individual is performing covered work and a break period is not provided, then a fatigue assessment is required to evaluate the individual's ability to safely and competently continue with covered work duties. If a break period is provided, that is less than 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months , a follow-up fatigue assessment is required before the individual can resume covered work duties.

NEI 06-11, Revision 2 April XXXXXX 20142016 72Self-Declaration Self-declaration of fatigue is a provision of the fatigue management program that allows individuals to formally notify supervision that they are not or may not be able to safely and competently perform their duties due to fatigue. This provision is not unlike similar notifications that an individual may make regarding the need to use medication and the possible resultant impact on fitness-for-duty. Licensee procedures must make a clear distinction between formal declarations of fatigue under the fatigue management program and casual comments such as being up late, being tired, etc. A fatigue assessment must be conducted in response to an individual's self-declaration to his or her supervisor that he or she is not fit to safely and competently perform his or her duties for any part of a work period because of fatigue, except if, following the self-declaration, the licensee permits or requires the individual to take a break of at least 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months before the individual returns to duty.

NOTE: Additional information regarding self-declaration is provided in Chapter 1412. Post-Event A post-event fatigue assessment is required in conjunction with drug / alcohol testing, which is invoked in response to events or circumstances as described in the licensee's FFD Program (refer also to 10 CFR 26.31(c)(3)(i) through (iii)). The primary purpose of the fatigue assessment is to determine if worker fatigue contributed to the event. If the event entails an injury to the affected individual, then necessary medical treatment must not be delayed in order to perform the fatigue assessment. In cases where the fatigue assessment is delayed by 10 or more hours, a fatigue assessment may not be useful in determining if worker fatigue contributed to the event. However, in these cases the fatigue assessment must still be performed. If medical treatment is not an issue and the affected individual is required to remain in a work capacity without a 10-hour break period, then the fatigue assessment is required to determine if that individual can safely and competently perform the assigned work duties without impairment due to fatigue. The Fatigue Assessor for a Post-Event fatigue assessment may not have:

o Performed or directed (on-site) the work activities during which the event occurred.

o Performed, within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months before the event occurred, a fatigue assessment of the individuals who were performing or directing (on-site) the work activities during which the event occurred.

NEI 06-11, Revision 2 April XXXXXX 20142016 73 o Evaluated or approved a waiver of the limits for any of the individuals who were performing or directing (on-site) the work activities during which the event occurred, if the event occurred while such individuals were performing work under that waiver. Follow-Up The purpose of the follow-up fatigue assessment is to determine if the individual is capable of safely and competently performing the assigned work duties without impairment due to fatigue. A follow-up fatigue assessment is required if a previous fatigue assessment was conducted for cause or due to a self-declaration, and if the individual is being returned to duty after a rest break of less than 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months , the need for controls and conditions must be assessed before permitting the individual to resume any duties.

13.3 FATIGUE ASSESSMENT ATTRIBUTES The fatigue assessment consists of two components:

A review of data pertaining to fatigue contributors. A face-to-face interview. Licensee policies typically describe the obligation on the part of the individual to be fit for duty. In the same way that drug and alcohol testing protocols provide a mechanism for measuring FFD with respect to substance abuse, the fatigue assessment protocol provides a mechanism for measuring FFD with respect to fatigue. The fatigue assessment may, in some circumstances, provide the basis for subsequent actions or sanctions under the licensee's fatigue management or disciplinary policies. The fatigue assessment is required to determine whether the individual is capable of safely and competently performing assigned duties without degraded alertness due to fatigue. There are certain restrictions on who may perform fatigue assessments. The fatigue assessments must be performed by FFD personnel or by a supervisor who is an authorized, trained fatigue assessor. If the individual being assessed is a contractor/vendor, the fatigue assessor may be a supervisor in the affected contractor/vendor organization, provided the supervisor is an authorized, trained fatigue assessor at that site. Fatigue Assessors The minimum training and examination requirements for a fatigue assessor are the same requirements as those described in Section 14 for all individuals who are in the FFD population.

NEI 06-11, Revision 2 April XXXXXX 20142016 74Among other FFD program topics this training addresses: Contributors to worker fatigue and decreased alertness in the workplace. Symptoms of worker fatigue. Indications and risk factors for common sleep disorders. Effective use of fatigue countermeasures. Licensees and contractor/vendors may require additional optional training for fatigue assessors, such as that available through the National Academy for Nuclear Training electronic learning portal (NANTeL).

NOTE: See post-event conditions below for further restrictions on fatigue assessors. The licensee may not conclude that fatigue has not or will not degrade the individual's ability to safely and competently perform his or her duties solely on the basis that the individual's work hours have not exceeded any of the work hour limits or that the individual has had the minimum breaks or minimum days off, as applicable. Following a fatigue assessment, the licensee shall determine and implement the controls and conditions, if any, which are necessary to permit the individual to resume performing duties for the licensee, including the need for a break.

13.4 REQUIRED INFORMATION At a minimum, the fatigue assessment must address the following factors: Acute fatigue. Cumulative fatigue. Circadian variations in alertness and performance. Individuals shall provide complete and accurate information that may be required by the licensee to address the required factors. Licensees shall limit any inquiries to only the personal information from the subject individual that may be necessary to assess the required factors. Review of individual performance as applicable.

13.5 P ROCESS FOR CONDUCTING FATIGUE ASSESSMENT NOTE: See specific requirements in the applicable sections of this guidance to ensure all attributes of the assessment are met for the specific condition requiring the fatigue assessment.

NEI 06-11, Revision 2 April XXXXXX 20142016 75 The process for conducting a fatigue assessment includes the following steps: Identification of condition requiring a fatigue assessment: Name of the individual. Date and time. Narrative supporting the condition requiring the fatigue assessment:

o For Cause-Description of observed behavior.

o Self-declaration-Description of current job duties, time in a duty status, and scheduled end of work period.

o Post-event-Description of the event and the individual's involvement.

o Follow-up-Length of rest period, reason for early return, and expected duties. Name, date, time, signature of individual completing this section. Work history for past 14 days as reported by the individual. Work history for the past 14 days as documented by the licensee. Statement of how the following were considered:

o Potential for acute fatigue-time since last 10-hour break and hours worked in the last 24 and 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months ..

o Potential for cumulative fatigue-review work history above.

o Determine if the individual has had the opportunity for two restorative rest periods, 34 hours3.935185e-4 days 0.00944 hours 5.621693e-5 weeks 1.2937e-5 months off in the last seven days.

o Circadian factors-time of day and recent work cycle.

o Observation and statements of the individual.

o Nature of work to be performed, for example, work that is solitary, sedentary, monotonous, performed in darkness, requiring sustained vigilance. Results of evaluation:

o Individual is fit for duty-return to full work status.

o Individual is not fit for duty due to fatigue-provide a minimum of a 10-hour break. o Individual is returned to duties with the following restrictions. Restrictions can include assignment to non-covered work, a nap before continuing covered work, etc. Name, date, signature of fatigue assessor. NRC edit NRC edit NEI 06-11, Revision 2 April XXXXXX 20142016 76 TABLE 13A: FATIGUE ASSESSMENT PROCESS [See rule for details - table provides only a general summary of the rule] Sub- section Fatigue Assessment Requirement Note 26.203(b)(3) Develop procedure for fatigue assessments Applies to individuals performing duties listed in Section 26.4(a)-(c) (i.e., all individuals subject to Subpart I) 26.203(b)(4) Develop procedure for disciplinary actions following a fatigue assessment Must include conditions and considerations for taking those disciplinary actions 26.211(a) Conduct fatigue assessment under the following conditions: - for cause - self-declaration

- post-event - follow-up For cause: in cases of an observed condition of impaired alertness, creating a reasonable suspicion, except during a break period Self-declaration: in cases of self-declaration unless the individual is permitted or required a rest break of at least 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months Post-event: in cases where post-event drug and alcohol testing is required Follow-up: if a previous fatigue assessment was conducted for cause or due to a self-declaration and if the individual is being returned to duty after a rest break of less than 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months ; the need for controls and conditions must be assessed before permitting the individual to resume any duties 26.211(b) Ensure persons conducting the Fatigue Assessment are trained and not subject to conflicts of interest Fatigue Assessment must be conducted face to face

Supervisors and FFD program personnel conducting Fatigue Assessments must be trained under Section 26.29 and 26.203(c)

For cause and post-event: the person conducting the assessment must be free of conflicts of interest, such as having approved a waiver prior to the event; see 26.211(b)(1) and (2) for details 26.211(c) Ensure fatigue assessment provides information necessary for management decisions and actions The assessment must address: acute and cumulative fatigue circadian variations in alertness and performance The inquiry must be limited to relevant information; the Individual must provide complete and accurate information 26.211(d) Licensee may not conclude that fatigue has not or will not degrade individual's performance solely on the basis that the individual did not exceed work hour control requirements

NEI 06-11, Revision 2 April XXXXXX 20142016 77 Sub- section Fatigue Assessment Requirement Note 26.211(e) Determine and implement controls and conditions necessary to resume duties Controls and conditions may include such things as: a rest break; peer-review and approval of job tasks; or assignment to job tasks that are non-repetitive (see SOC p.17153) 26.203(d)(5)and 26.211(f) Document fatigue assessment results Must document the reasons for and results of any fatigue assessment conducted, the circumstances, and the controls and conditions implemented 26.203(d)(5)and 26.211(g) Prepare annual summary report Prepare the annual summary report of fatigue assessments conducted for covered individuals during the previous calendar year at each NPP site; see 26.211(g)(1)-(4) for details

NEI 06-11, Revision 2 April XXXXXX 20142016 78 TABLE 13B: "SUPERVISORY ASSESSMENT OF FITNESS" FOR WAIVERS VS. "F ATIGUE ASSESSMENT" [See Rule for details - table provides only a general summary of the rule] Item Super visory Assessment of Fitness for Waivers -

26.207(a)(1)(ii)

FatigueAssessment

- 26.211 Purpose Assess individual for a waiver

Following these conditions:

o For cause o self-declaration o post-event o follow-up (before return to duty in certain specified cases)

See 26.211(a)(1)-(4) for specific details Who can perform Supervisor trained and qualified to direct or oversee work

Trained supervisor or trained FFD program personnel with no conflict of interest How Face-to-face

Face-to-face

Requires accurate info from worker and constrains licensee to ask only pertinent questions Timing Not more than 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months before the individual begins performing any work under the waiver

Depends on the triggering condition

Post-event fatigue assessment must occur as soon as practical after event Scope

Acute and cumulative fatigue, circadian variations

Whether already fatigued

Whether will be fatigued by end of period waiver covers

Acute and cumulative fatigue, circadian variations

Not to be determined solely by compliance status with work hour controls

NEI 06-11, Revision 2 April XXXXXX 20142016 79 14 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): Knowledge of the contributors to worker fatigue, circadian variations in alertness and performance, indications and risk factors for common sleep disorders, shift work strategies for that shift workers can use to obtain ing adequate rest, and the effective use of fatigue countermeasures. Ability to identify symptoms of worker fatigue and contributors to decreased alertness in the workplace. Employees and contractors of the licensee should be aware of the trustworthiness and reliability requirements for unescorted access to the protected area, the importance of being fit for duty, understand the potential consequences of working while fatigued, and work in compliance with the station FFD policy. Workers should be able to: Demonstrate knowledge of the basic fatigue management requirements for workers. Recognize the personal, public health, and safety hazards associated with fatigue. Discuss the company fatigue management policy. Discuss individual roles and responsibilities under the company fatigue management policy. Demonstrate knowledge of the contributors to worker fatigue, circadian variations in alertness and performance, indications and risk factors for common sleep disorders, shift work strategies for that shift workers can use to obtain ing adequate rest, and the effective use of fatigue countermeasures. Demonstrate understanding of identifying symptoms of worker fatigue and contributors to decreased alertness in the workplace. Demonstrate understanding of fatigue management techniques. Discuss the methods used to implement the company fatigue management policy. Discuss the consequences of not following the company fatigue management policy. Discuss individual and company rights regarding the company fatigue management policy. Each test is to include at least one question from each KA. The rest of the test should be a random sample of questions from all the remaining KAs. NRC edit highlighted

,for that shift workers can use to ob tai n ing NRC edit highlighted

, s for that shift workers can use toobtain ing NEI 06-11, Revision 2 April XXXXXX 20142016 80 15 RECORDS Licensees shall retain the following records for at least three years or until the completion of all related legal proceedings, whichever is later: Records of work hours for individuals who are subject to the work hour controls. Records of shift schedules and shift cycles of individuals who are subject to the work hour controls. The documentation of waivers including the bases for granting the waivers and the supervisory assessments. The documentation of work hour reviews. The documentation of fatigue assessments. Table 15 is provided for reference.

NEI 06-11, Revision 2 April XXXXXX 20142016 81 TABLE 15: DOCUMENTS , REPORTS , AND R EVIEWS REQUIRED UNDER SUBPART I [See rule for details - table provides only a general summary of rule] Item Sub-section Type of Document, Report, Review Description 1 26.203(a) Policy on Fatigue Management Written policy for the management of fatigue for all persons subject to FFD Program Include as part of the written FFD policy required under 26.27 2 26.203(b)(1) Procedure for Self- declaration Written procedure describing the process to follow when an individual makes a self-declaration that he/she is not fit to safely and competently perform duties as a result of fatigue; see details in 26.203(b)(1)(ii)-(iii) 3 26.203(b)(2) Procedure on Work Hour Controls Written procedure describing the process for implementing work hour controls under Section 26.205 4 26.203(b)(3) Procedure for Fatigue Assessments Written procedure describing the process for conducting fatigue assessments under Section 26.211 5 26.203(b)(4) and 26.77(b)(2) Procedure for Disciplinary Actions Written description of the disciplinary actions and the conditions and considerations that may be imposed following a fatigue assessment 6 26.203(c) Additions to FFD Training Program Addition of specific knowledge and abilities (KAs) on fatigue management to the FFD training requirements under Section 26.29(a); see details of KAs to be included in 26.203(c)(1)-(2) 7 26.203(c) Additions to Comprehensive FFD Examination Addition of specific KAs on fatigue management to the FFD comprehensive examination requirements under Section 26.29(b); see details ofKAs in 26.203(c)(1)-(2) 8 26.203(d)(1) Records of work hours Records of work hours of individuals subject to Section 26.205 must be created and retained for 3 years or until completion of all legal proceedings 9 26.203(d)(2) Records of shift schedules and shift cycles Records of shift schedules and shift cycles of individuals subject to Section 26.205 must be created and retained for 3 years or until completion of all legal proceedings NEI 06-11, Revision 2 April XXXXXX 20142016 82Item Sub-section Type of Document, Report, Review Description 10 26.203(d)(3) and 26.207(a)(4) Documentation of waivers Documentation of waivers granted under Section 26.207, including bases for granting the waiver and supervisory assessment must be created 11 26.203(d)(4) and 26.205(e)(3)- (4) Documentation of work hour reviews (effectiveness reviews) Documentation of work hour reviews required under Section 26.205(e), including methods used, results, problems, and trends and corrective actions 12 26.203(d)(5) and 26.211(f) Documentation of fatigue assessments Documentation of the results of any fatigue assessment conducted, including circumstances and controls and conditions implemented 13 26.203(d)(5) and 26.211(g)

Annual Summary of Fatigue Assessments Annual summary report of fatigue assessments conducted during the previous calendar year for any individual identified in Section 26.4(a)-(c); required for each NPP site; see 26.211(g)(1)-(4) for details 14 26.203(e)(1) and 26.717 Addition to Annual FFD Program Performance Report: Summary of Waivers of Work Hour Controls A summary of waivers from the previous calendar year for each NPP site; see 26.203(e)(1)(i)-(iii) for details, included in the Annual FFD Program Performance Report 15 26.203(e)(2) and 26.717 Addition to Annual FFD Program Performance Report: Corrective Actions Summary A summary of the corrective actions, if any, resulting from the analyses of waiver data, included in the Annual FFD Program Performance Report 16 26.203(f)

Addition to audit process An audit of the management of worker fatigue is part of the FFD audit requirements in Section 26.41 17 26.205(d)(8) Policy and Procedure Regarding Use of MDOs and/or 54-Hour Alternative The FFD policy and procedures should state which alternative the licensee is complying with: MDO or maximum average work hour (MAWH) requirements NEI 06-11, Revision 2 April XXXXXX 20142016 83 Item Sub-section Type of Document, Report, Review Description 18 26.719 Significant FFD policy violations or programmatic failures Violations of Subpart I or failures of a licensee's Fatigue Management Program are reported according to the procedures in 26.719 (Note that this requirement is not specifically referenced in Subpart I)

NEI 06-11, Revision 2 April XXXXXX 20142016 84 16 REVIEWS Licensees shall evaluate the effectiveness of their control of work hours of individuals who are subject to this section.

16.1 ANNUAL W ORK H OUR CONTROL EFFECTIVENESS REVIEW Licensees shall conduct the reviews once per calendar year. If any plant or security system outages or increased threat conditions occurred since the licensee completed the most recent review, the licensee shall include in the subsequent review an evaluation of the control of work hours during the outages or increased threat conditions. Licensees shall complete the review within 30 days of the end of the review period. The review period should be defined by the licensee. Content of Annual Review Review the actual work hours and performance of covered individuals during the entire review period, including any plant or security system outages or increased threat conditions, for consistency with the work hours scheduling requirement objective of preventing impairment from fatigue due to the duration, frequency, and sequencing of hours worked.

o The review should be based on information in, but not limited to, the corrective action program.

o At a minimum, this review should address the following: When using the on-line MDO method, individuals whose actual hours worked during the review period exceeded an average of 54 hours6.25e-4 days 0.015 hours 8.928571e-5 weeks 2.0547e-5 months per week in any shift cycle. When using the on-line averaging method, individuals whose actual hours worked exceeded an average of 54 hours6.25e-4 days 0.015 hours 8.928571e-5 weeks 2.0547e-5 months per week in any averaging period of up to 6 weeks. Individuals whose actual hours worked during the review period exceeded an average of 54 hours6.25e-4 days 0.015 hours 8.928571e-5 weeks 2.0547e-5 months per week in any shift cycle while the individuals' work hours were subject to the non-outage day-off requirements. Individuals who were granted more than one waiver during the review period. Individuals who were assessed for fatigue during the review period. If work under a waiver occurred, review the individuals' hours worked and the waivers under which work was performed to evaluate staffing adequacy for all jobs subject to the work hour controls. Review performance of the station in adhering to work schedules for covered work groups: evaluate whether or not the schedule is effectively being implemented.

NEI 06-11, Revision 2 April XXXXXX 20142016 85 o Is the schedule being adhered to?

o Are the changes understood and reasonably consistent with a properly managed schedule?

o Does the overtime utilized support efficient utilization of resources?

o Are the available resources properly aligned with the scheduled work load?

o Is unplanned work or outages indicative that other corrective actions are necessary?

o Does the level and pattern of overtime support a determination that staff size is appropriate for the schedule and work?

o Are chronic self-declarations due to scheduling deficiencies? Documentation and Follow-up Document the methods used to conduct these reviews and the results of the reviews. Record, trend and correct, under the licensee's corrective action program, any problems identified in maintaining control of work hours consistent with the specific requirements and performance objectives of the rule.

NOTE: Refer to Table 15 in Section 15, Records, for a general summary of documents, reports and reviews required under 10 CFR 26 Subpart I.

NEI 06-11, Revision 2 April XXXXXX 20142016 86 TABLE 16: WORK H OUR CONTROL EFFECTIVENESS REVIEW P ROCESS [See rule for details - table provides only a general summary of the rule] Sub-section Review Requirement Purpose Note 26.205(e) Conduct work hour control effectiveness reviews once per calendar year Evaluate the effectiveness of control of work hours of individuals subject to the work hour control requirements Include in the review any plant or security system outages or increased threat conditions that occurred since the last review Review must be completed within 30 days of the end of the review period 26.205(e)(1) Review actual work hours and performance of certain covered individuals for consistency with scheduling requirements of 26.205(c) Review actual hours worked and worker performance to examine if licensee scheduling practices meet objective of preventing impairment from fatigue due to duration, frequency or sequencing of shifts (26.205(c))

At minimum, review must include individuals:

whose actual hours worked exceeded an average of 54 hours6.25e-4 days 0.015 hours 8.928571e-5 weeks 2.0547e-5 months per week in either:

o any shift cycle with covered work subject to 26.205(d)(3) MDOs or o any averaging period up to 6 weeks (as per licensee averaging period) for covered work subject to 26.205(d)(7)

who were granted more than one waiver

who were assessed for fatigue while being considered for a waiver under 26.211 [fatigue assessment] 26.205(e)(2) Review individuals' hoursworked and waivers under which work was performed Evaluate staffing adequacy for all jobs subject to work hour controls Only waivers under which work was performed must be reviewed; if waiver was granted but not utilized, it does not need to be included in the review 26.205(e)(3) Document the methods used to conduct the review and the results of the review Provide basis for evaluation and corrective action 26.205(e)(4) Record, trend and correct, under the corrective action program, any problems identified Address problems identified in maintaining control of work hours consistent with specific requirements as well as performance objectives of Part 26 NEI 06-11, Revision 2 April XXXXXX 20142016 87 17 REPORTING 17.1 ANNUAL REPORTING REQUIREMENTS Licensees shall report fatigue rule information in a standard format in the annual FFD program performance report required under § 26.717. Reports related to fatigue management can be integrated into the overall FFD report and can be submitted electronically. 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. Fitness-for- Duty reporting consists of one of two methods: Electronic Information Exchange (EIE) Using the General Submission Portal. This is the preferred and easiest method of reporting and consists of licensees completing one or more of the three types of FFD forms using the General Submission portal. The completed forms will be in a

.pdf format, which the licensee can submit electronically to the NRC. In order to satisfy the annual reporting requirement for Fatigue Management, use the FFD Form linked below when making an electronic submittal through the EIE General Submission portal: http://pbadupws.nrc.gov/docs/ML1135/ML113530456.pdf. Hard Copy. Although this is the less desirable method, licensees may still submit hard copy FFD performance reports. This is the least desirable method because the FFD hard copy reports are in site-specific formats, nomenclature and level-of-detail making it difficult for the NRC staff to understand and evaluate site-specific corrective actions and results and data contained within the hard copied reports needs manual data extraction methods to facilitate industry-wide trending.

17.2 ANNUAL

SUMMARY

OF WAIVERS A summary shall be provided for each nuclear power plant site of all instances during the previous calendar year in which the licensee waived the work hour controls for individuals described in Section 5, Managing Fatigue, and Section 6, Work Hour Controls. The summary must include only those waivers under which covered 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 shall 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: The number of instances in which each work hour control was waived for individuals not working on outage activities.

NEI 06-11, Revision 2 April XXXXXX 20142016 88 The number of instances in which each work hour control was waived for individuals working on outage activities. A summary that shows the distribution of waiver use among the individuals within each category (e.g., a table that shows the number of individuals that received only one waiver during the reporting period, the number of individuals that received a total of two waivers during the reporting period, etc.). A summary of corrective actions, if any, resulting from the analyses of these data, including fatigue assessments.

NOTE: Refer to Table 15 in Section 15, Records, for a general summary of documents, reports and reviews required under 10 CFR 26 Subpart I.

17.3 ANNUAL

SUMMARY

OF FATIGUE ASSESSMENTS Licensees shall prepare an annual summary for each nuclear power plant site of instances of fatigue assessments that were conducted during the previous calendar year for any individual identified in § 26.4(a) through (c). Each summary must include: The conditions under which each fatigue assessment was conducted (i.e., self-declaration, for cause, post-event, follow-up). A statement of whether or not the individual was working on outage activities at the time of the self-declaration or condition resulting in the fatigue assessment. The category of duties the individual was performing, if the individual was performing the duties described in § 26.4(a)(1) through (a)(5) at the time of the self-declaration or condition resulting in the fatigue assessment. The management actions, if any, resulting from each fatigue assessment.

NOTE: Refer to Table 15 in Section 15, Records, for a general summary of documents, reports and reviews required under 10 CFR 26 Subpart I.

17.4 I NCIDENT REPORTING REQUIREMENTS Within a 24-hour limit, licensees are required to report significant FFD policy violations or programmatic failures under § 26.719(b). NOTE: The requirements in § 26.719(b)(1) and (b)(2) originated in the previous FFD rule and refer to drug and alcohol issues. The requirement at § 26.719(b)(3) addresses any intentional act that casts doubt on the integrity of the FFD program.

NEI 06-11, Revision 2 April XXXXXX 20142016 89 Since no reporting requirements were specifically identified for fatigue management incidents, an equivalency judgment will need to be made when an incident occurs. A few examples are as follows: A conflict of interest when performing a fatigue assessment may reach the threshold of a significant FFD policy violation. Events or a series of events which, in the judgment of management, indicate a significant systemic failure of the fatigue management program, procedures or policies or failure to meet key objectives related to safety. A significant attempt by a supervisor to subversively violate the fatigue management program. NOTE: Refer to Table 15 in Section 15, Records, for a general summary of documents, reports and reviews required under 10 CFR26 Subpart I.

NEI 06-11, Revision 2 April XXXXXX 20142016 90 18 AUDITS Licensees shall audit the management of worker fatigue as required by § 26.41.

18.1 CONDUCT OF AUDITS Audits shall focus on the effectiveness of the FFD program element, Fatigue Management, and shall be conducted by individuals who are qualified in the subject(s) being audited. The individuals performing the audit of the program shall be independent from both the subject FFD program's management and from personnel who are directly responsible for implementing the FFD program. Audits shall be conducted each 24 months in accordance with the license's audit program.

18.2 AUDIT RESULTS The result of the audits, along with any recommendations, shall be documented and reported to senior corporate and site management. Each audit report shall identify conditions that are adverse to the proper performance of the FFD program, the cause of the condition(s) and, when appropriate, recommended corrective actions. The licensee or other entity shall review the audit findings and take corrective actions, including re-auditing of the deficient areas where indicated to preclude, within reason, repetition of the condition. The resolution of the audit findings and corrective actions shall be documented.

NOTE: Refer to Table 15 in Section 15, Records, for a general summary of documents, reports and reviews required under 10 CFR 26 Subpart I.

NEI 06-11, Revision 2 April XXXXXX 20142016 91 19 PERSONNEL ACTIONS Individuals that exhibit chronic self-declaration that they are not fit for duty as a result of fatigue should be considered for referral to the employee assistance program. Individuals who exhibit chronic self-declaration that they are not fit for duty as a result of fatigue, absent a sound medical reason, may be subject to disciplinary action. Personnel are required to be fit for duty and getting sufficient rest is required to ensure a person is not subject to fatigue. Persons who make choices that result in less than the sleep necessary for that person to remain alert and avoid fatigue are not meeting their obligation per this rule. The refusal on the part of an individual to submit to a supervisory assessment or fatigue assessment shall subject the individual to disciplinary action and possible removal from unescorted access. Facts to be considered in assessing disciplinary action shall include the employee's job assignment, past work record and work schedule. Personnel subject to the fatigue assessments who refuse to be assessed will be considered fatigued and unable to perform their duties. Time away from work for fatigue management recovery shall be classified as vacation, personal time (if available) or non-paid time.

NEI 06-11, Revision 2 April XXXXXX 20142016 92 20 EXAMPLES Example 1: Unescorted Access If a non-badged contractor is brought on site to do emergent critical specialty work on a risk-significant component (such as a contractor who is sealing a risk-significant valve), is that contractor subject to the work hour limitations? Note that the contractor would be escorted.

Answer: Personnel under escort (i.e., non-badged individuals) are not subject to work hour limitations. Example 2: Removal of Risk-Significant Component From a System A risk significant component is removed from site to be refurbished or repaired. Is the off-site work on this component considered covered work? Answer: No, work on a component that is off site is not covered work. The work for removal, installation and testing the component is covered work. Example 3: Risk Significance Status When in Outage Part 26 states to use 10 CFR 50.65(a)(4) for determining safety significance of systems but many items in a(4) are not safety-significant during outages. For example, auxiliary feedwater is not risk-significant during an outage. Must the work be covered during an outage? Answer: The auxiliary feed water system is safety significant when the unit is operating. If an individual works on the auxiliary feed water system either during an outage or operations, the individual would be considered to be subject to the work hour controls. Example 4: Directing Example 4A: On Sunday morning at 0400, while running the #1 Diesel Generator (DG), a problem develops that requires the system engineer to return to site to provide technical assistance. The maintenance crew performing work on the #1 DG is being supervised by a first-line maintenance supervisor. The system engineer provides technical information and makes recommendations to the maintenance supervisor. Is the system engineer a covered individual? Answer: The system engineer is providing information to the supervisor of a maintenance crew. The maintenance supervisor in this case would be responsible for deciding what information is to be acted on and for directing the maintenance activities associated with the job. The system engineer is not directing and therefore not performing covered work.

NEI 06-11, Revision 2 April XXXXXX 20142016 93 Example 4B

A DG system engineer is supporting a diesel generator system window by providing technical decisions in the field directly to workers who are acting on the input without subsequent review or challenge by the job supervisor. Is the system engineer directing? Answer: Yes, the system engineer is directing as defined by the rule as the covered workers are taking and acting on the input provided by the engineer without subsequent review, challenge or decision-making processing by a supervisor. Example 4C: The reactor engineer is required by station procedures to be present during fuel movement. The reactor engineer's function is to observe the fuel movement activity and provide technical recommendations to the fuel-handling SRO. Is the reactor engineer a covered individual? Answer: The reactor engineer is not directing; they are providing technical information and observing and therefore not conducting covered work. The fuel-handling SRO would be directing and is a covered individual. Example 4D: The reactor engineer is required by station procedures to be present during reactor startup. The Reactor Engineer's function is to provide information to the control room supervisor on the reactivity of the reactor during the approach to criticality. Is the reactor engineer a covered individual? Answer: The reactor engineer is not directing; they are providing technical information and therefore not conducting covered work. The control room supervisor would be directing and is a covered individual. Example 4E: Give clarification of what activities the supervisor is a covered employee due to directing. Answer: The following tasks are examples generally considered NOT directing:

Engineering tasks. Supervision in the plant of the maintenance on a non-risk-significant SSC. Supervision at the second-level supervision. NOTE: Position alone should not be the deciding factor. For example a shift manager is a second-level supervisor but, in practice and as defined in 10 CFR 26.4, has the authority to direct covered activities. Careful analysis, evaluating all the criteria, should occur prior to determining applicability or exclusion. Conducting Work Control Center documentation activities.

NEI 06-11, Revision 2 April XXXXXX 20142016 94 Writing a work procedure. Preparing a work or modification package. Review by senior management of work plans. Training of personnel during which time the trainee is not operating or performing maintenance activities. Providing recommendations from vendors and engineers on test performance, component and system operation or other similar technical inputs. Review and approval of documents. Any work that is not operations or maintenance on risk-significant SSCs. Technical staff providing only recommendation to control room staff. Example 5:

34-Hour Break Assume that John Doe is a staff engineer in the operations department who holds an active license. John's applicable shift schedule is an works a nominal eight-hour day. John's normal work duties are NOT within the scope of the work hours rule. Over the last six weeks, John has had weekends off except for the sixth week. During the sixth week (i.e., last week) John worked Monday through Friday, came in on Saturday for 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to catch up on work, and also came in Sunday for four hours. John resumed his normal duties on Monday this week. Today (Tuesday)

John is asked to stand an eight-hour shift schedule SRO watch. Can he stand the watch since Tuesday is the ninth day in a row that John will be working?

Answer: No, John has not had a 34-hour break in the last 216-hour (9-day) period nor has John had a day off in the last 7 days. Example 6:

34-Hour Break and MDO Assume that Jane Doe is a staff engineer in the operations department who holds an active license. Jane's works aapplicable shift schedule is an nominal 8-hour day. Jane's normal work duties are NOT within the scope of the work hours rule. Over the last six weeks Jane has had weekends off, except that Jane, as a normal routine

, works hours every Saturday morning. Jane resumed her normal duties on Monday this week. Today (Tuesday) Jane is asked to stand a 12-hour shift schedule SRO watch. Can she stand the watch? Answer: Yes, Jane has had a 34-hour break in the last 216 hours0.0025 days 0.06 hours 3.571429e-4 weeks 8.2188e-5 months (9 days). Jane also has worked less than 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months in the last 168-hour (7-day) period. Jane works an 8-hour shift and a look back over the last 7 days shows that she does meet the minimum 1 day off requirement to transition to covered work. Example 7: Average Shift Length MDO Requirement and Other Limits Assume that John Smith works in the energy delivery part of his company and sometimes is needed to perform covered work in the switchyard of the nuclear plant. He has unescorted access to the plant, but only works here occasionally when needed. The rest of the time, he works out on Commented [A10]: Alternative: "John works a schedule that averages eight hours per workday over the shift cycle."

Commented [A11]: Alternative: "Jane works a schedule that averages eight hours per workday over the shift cycle."

NRC edit NRC edit NRC edit NEI 06-11, Revision 2 April XXXXXX 20142016 95 the distribution system. What are the requirements for John to start performing covered work in the switchyard? Answer: If John's average shift length in the preceding 7 days is 9 hours1.041667e-4 days 0.0025 hours 1.488095e-5 weeks 3.4245e-6 months or less, he requires 1 day off in the preceding 7 days. If his average shift length is greater than 9 hours1.041667e-4 days 0.0025 hours 1.488095e-5 weeks 3.4245e-6 months , he requires 2 days off in the preceding 7 days. In addition the following maximum work hours and minimum breaks apply prior to performing covered work: 16 work hours in the preceding 24-hour period. 26 work hours in the preceding 48-hour period. 72 work hours in the preceding 168-hour (7-day) period. A 10-hour break between the previous work period or an 8-hour break between the previous work period when a break of less than 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months was necessary to accommodate a crew's scheduled transition from an outage to online operations. A 34-hour break in the preceding 216-hour (9-day) period. Example 8: Call-In Work Period An individual's normal schedule is from 0700 to 1530 (8-hour day) and the individual is called back to work (emergent site security issue) at 1900 and he/she works until 2100. The separate work period method cannot be used since a 10-hour break is not available prior to the call-in period. The call-in is considered an extension of the previous work period, 0700 to 1530. The hours counted for this work period would be 14. A 10-hour break is required prior to the individual starting an additional work period; therefore, the individual could return at the normal start of their work period at 0700 the next day. A waiver to the 10-hour break between successive work periods could be performed. The hours counted for the work day would be 10.5. The individual could return at the normal start of their work period at 0700 the next day. Example 9: Call-In Work Period An individual's normal schedule is from 0700 to 1530 (8-hour day), and the individual is called back to work from 0200 to 0400 the next day. The call-in period is considered a separate work period. The 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months worked for the licensee is counted. The individual had a 10-hour break prior to the start of the work period and must be given a 10-hour break following the end of the work period. The call-in is considered an extension of the succeeding work period, 0700 to 1530. The hours counted for this work period would be 13.5. A waiver should not be necessary in this example.

NEI 06-11, Revision 2 April XXXXXX 20142016 96Example 10:

Phone Call at Home - Incidental Duties An individual performs risk-significant work for 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months (0700-1700) and goes home. At 2200 he/she receives a call from work and talks for 1-hour until 2300. Can he/she return to work at 0700 the next day?

Answer: The individual did not have a 10-hour break prior to receiving the call. The hours from 1700 through 2200 do not count with respect to calculating hours worked. The individual worked a total of 11 hours1.273148e-4 days 0.00306 hours 1.818783e-5 weeks 4.1855e-6 months with the work period ending at 2300. However, the individual cannot return to work at 0700 the next day; he/she would not meet the 10-hour break requirement. The individual could begin work at 0900 the next day.

Example 11

Phone Call at Home - Incidental Duties If an individual is on a day off and is required to talk with licensee personnel at the plant on 3 occasions, with each call lasting 20 minutes, totaling one hour, can that day still be considered a day off since that one hour shall be included in the work hour total? Answer: The total time spent on the phone shall be counted since it exceeds a nominal 30 minutes during a single break period; therefore, the total time spent on the telephone call must be documented as an hour worked for MAWH. The day is considered a work day for MDO purposes. Example 12: Day-Off and Work at Home What "work-related" activities may be done at home on a day off without violating the "day off" intent? For example, may an individual read procedures, catch up on administrative tasks or study for a license requalification exam for a number of hours and still count that day as a "day off"? Answer: Activities initiated by the individual (not required by or performed for the licensee) may be performed at home on a day off and not be considered "work," e.g., studying, reading work-related material, reading email. These activities would not violate the 30-minute incidental duties requirement and would, therefore, not be counted toward the work hour total

. If the licensee would downgrade the individual if he or she did not perform this activity, then the activity should be considered to be required by the licensee and therefore included in the calculation of the individual's work hours.

Example 13: Outage Minimum Day Off Extension If during the first 60 days, a covered worker gets a 7-day block where he works not more than 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months , you can extend the 60-day period by 7 days. If the worker gets two 7-day blocks where he does not work more than 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months and the two periods do not overlap, can you extend the 60-day period by 14 days? Answer: Yes, you can extend the 60-day period by 14 days. This extension can be made any time in the outage period after the less than 48-hour work week. Since this extension is calculated by a week defined as seven days and if every week of the initial 60 days is used for Commented [A12]: Retain from RG 5.73. NRC edit NRC edit NEI 06-11, Revision 2 April XXXXXX 20142016 97 the extension only 56 days (eight weeks) are available for the extension. The 48-hour allowance can only be banked during the first 60 days of the outage and used no later than day 116 of the outage. Example 14: Outage Minimum Day Off Extension An individual has not worked for a licensee on a nuclear unit outage with work hour controls for 14 days. The individual starts work on outage day 15. Can the worker be placed under the outage work hour controls only for a period of 45 days? Answer: The 60-day period is defined by the start of the outage. The worker can be placed under the outage work hour controls only for a period of 45 days. The worker may also be available for a 14-day extension if the worker did not work more than 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months during each of the prior weeks. A worker that was on vacation during the 14-day period would be eligible for a 14-day extension. This extension for outage work hour controls cannot be extended into non-outage periods. Example 15: Forced Outage Truncating On-Line Shift Cycle What does it look like to be in compliance if the schedule would have been in compliance should the forced outage not have occurred? Conditions: Plant Online Week 1 (Days 1-7), Forced Outage Weeks 2-5 (Days 8-35). After Week 1, crews adopt outage schedule, adhering to outage work hour restrictions. Work schedule Plant status = Normal OperationsTypcal Schedule - Operations CrewsD = 12-hour day shift from 7 a.m. to 7 p.m.N = 12-hour night shift from 7 p.m. to 7 a.m.T = 10-hour training shift from 7:30 a.m. to 5:30 p.m.Total cycle is for a 5-crew, 35-day rotation.Crew/Day1234567891011121314151617181920212223242526272829303132333435MTWTFSSMTWTFSSMTWTFSSMTWTFSSMTWTFSSANNNNDDDDTTTTDDDNNN BDNNNNNNNDDDDTTTTDD CTTTTDDDNNNNNNNDDDD DDDDDTTTTDDDNNNNNNNENNNDDDDTTTTDDDNNNNLegendDay ShiftNight ShiftTraining Days Off Per Week, Averaged Over Shift Cycle During Periods of Normal Operations (i.e., During Week 1) Crew A: 6 Crew B: 3 Crew C: 1 NEI 06-11, Revision 2 April XXXXXX 20142016 98Crew D: 3 Crew E: 4 Answer: The above schedule shows that the licensee was currently in compliance and would have been in compliance with the minimum days off over the remainder of the shift cycle and thus is considered in compliance with the rule when transitioning to the unplanned outage work hours. Each crew has an average of 3.4 days off per week over the five weeks (17 days off/five weeks). The licensee then must meet the outage work hour requirements during the outage. Example 16: Outage Activities Provide some actual activities that are considered outage activities. Answer: Outage activities are activities associated with the outage unit and common systems including covered and non-covered tasks performed while the unit is disconnected from the electrical grid.

Examples of unit outage activities include but are not limited to the following: Activities included in the outage schedule. Planning and scheduling activities. Emergent work that impacts the outage unit. Review and impact of activities included in the outage schedule. Switchyard activities. Corrective maintenance. Elective maintenance. Preventive maintenance. Calibrations. Safety tagging. Staging of equipment and tools. Valve lineups and verifications. System readiness inspections. Post-maintenance testing. Surveillance testing. System walk-downs. Containment mobilization and demobilization. Refueling.

NEI 06-11, Revision 2 April XXXXXX 20142016 99 Fuel movement in the spent fuel pool. Housekeeping walk-downs and inspections. FME activities. Management observations. Operation, monitoring and alarm response of outage systems and common systems. Operation, monitoring and alarm response of stand-alone systems required to support the outage unit such as auxiliary boiler. Construction activities. Scaffold installation and removal. Temporary power installation and removal. Decontamination activities. Radiation protection activities. Processing of waste water. Outage work control and communication. Participation in pre- and post-job briefs for outage tasks and common systems. Outage unit project coordination. Testing of component on the outage unit or common systems. Pre- and post-shift turnover briefing of outage unit and common systems. Sampling of outage unit and common systems. Chemical addition to outage unit and common systems. Post-event investigation for outage unit and common systems. Receipt of materials in support of the outage. Just in time training of outage activities. Example 17: Infrequent Status Checks After leaving site, a reactor operator who was relieved "at the controls" receives a telephone call about a component switch on the control board with a red tag that became unattached. The telephone call lasts less than 10 minutes and was before the relieved operator entered his traditional sleep period. Does this count as incidental time?

Answer: No, if the call was one time only of short duration (less than 30 minutes), then there is no impact to fatigue and can be excluded from consideration of incidental time. If the telephone call interrupted the operator's sleep period, then the supervisor authorizing the call should consider the impact of fatigue if the operator is required to be at work the next work shift.

NEI 06-11, Revision 2 April XXXXXX 20142016 100Example 18A: A Freeze Seal watch is in containment to ensure that the freeze seal is being maintained in order to provide a safe work boundary per the stations clearance and tagging program, while the reactor coolant system is open for maintenance. His actual turnover takes approximately 15 minutes; however, due to the congestion at the control point, RP dress out at shift change, took another 30 minutes. Can the total time for turnover and dress-out be excluded from work hour calculations? Answer: Yes, if this time occurred outside the individual's scheduled work period, because the turnover occurred. In this case the relief was between two individuals on contiguous shifts that needed to be face-to-face and required the individual to dress-out at shift change, and the compliance with radiological safety requirements must be adhered to. Example 18B: Valve services technicians are working in containment, on a component that is on critical path for the outage schedule. At the end of their shift, they plan on relieving "on-station" to adhere to the stations outage schedule. The incoming technicians will need to dress out (15 minutes) and conduct relief (15 minutes) at the valve location inside containment. Can the 30 minutes be considered turnover? Answer: No. In this case, a face-to-face turnover was desired to maintain schedule adherence. The work could have been stopped, and the turnover could have been conducted in the shop or outside containment. In summary, a face-to-face turnover between contiguous shifts was not required.

Example 18C: A security officer is stationed at a remote post on the perimeter of the owner-controlled area of a site. In addition to the normal time for turnover of the security post, 20 additional minutes are accrued in transit back to security headquarters to dis-arm. Can the 20 minutes in transit be excluded as part of turnover? Answer: Yes. Example 18D: An outgoing plant chemist is turning over to the oncoming shift chemist. The individuals are part of minimum shift staffing. There is no sampling in progress. The site provides a nominal 20 minutes of turnover time for the chemists. Can the turnover time be excluded, although no safety-related activity is in progress? Answer: Yes. It is recognized that covered individuals may not be performing a covered activity every moment they are on shift. It is acceptable to exclude that portion of shift turnover that occurs outside the individual's scheduled work period provide nominal turnover when face-to-face turnover between contiguous shifts is required,time regardless of the activity in progress. Commented [A13]: Revise to eliminate specification of a nominal turnover time.

NRC edit NRC edit NRC edit NEI 06-11, Revision 2 April XXXXXX 20142016 101 21 REFERENCES AND RESOURCES 10 CFR 26 Fitness for Duty Programs Regulatory Guide 5.73 Fatigue Management for Nuclear Power Plant Personnel Federal Register Notice Volume 73, Page 16966, dated March 31, 2008 SECY 06-0244 Final Rulemaking - Part 26 Fitness for Duty Programs SECY 09-0183 Inclusion of QC/QV Personnel Within Scope of Subpart I SECY 11-0028 Alternative to MDO provisions of 10CFR26 Subpart I NUREG CR-4248 Recommendations on Scheduling and Overtime for NPP NUREG-1912 Summary and Analysis of Public Comments for 10CFR Part 26 FFD Programs ML11189A177 Managing Personnel Fatigue at Nuclear Power Reactor Sites ML12320A581 Summary of Public Meeting, Oct. 18, 2012, for Part 26 Subpart I EGM-09-008 Enforcement Manual Change Notice - Dispositioning Violations of NRC Requirements for Work Hour Controls Before and Immediately After a Hurricane Emergency Declaration," dated Sept. 24, 2009 ML13052A776 Summary of Public Meeting, Jan 28, 2013, for Part 26 Subpart I ML13127A414 Summary of Public Meeting, Apr.11, 2013, for Part 26 Subpart I ML13211A211 Summary of Public Meeting, Jul. 16,, 2013, for Part 26 Subpart I ML13290A524 Summary of Public Meeting, Sept 18,2013, for Part 26 Subpart I ML13364A030 Summary of Public Meeting, Dec 4, 2013, for Part 26 Subpart I ML14015A198 1 14 14 NRC Staff review of NEI 06 11 Rev 2f.

NEI 06-11, Revision 2 April XXXXXX 20142016 102NEI 06-11 Rev 2 Reference Aids - Tables and Graphics Definitions Terms Relevant to Fatigue Management LIST OF TABLES Table 1 Other Part 26 Sections Applicable to Subpart I Table 2A Subpart I Requirements for Different Categories of Individuals Table 2B Individuals Subject to Work Hour Controls Table 7 What to Include/Exclude When Calculating Work Hours Table 9A Work Hours Controls - Normal Operations Table 9B Work Hours Controls - Outage Table 9C Applying Each Control - Work Hour Limits and Rest Break Requirements Table 9D Applying Each Control - MDOs and 54-Hour Alternative Table 10 Transitions Out of Outage Table 11A Waiver Process Table 11B Waivers and Exceptions to Work Hour Controls Table 12 Self-Declaration Process Table 13A Fatigue Assessment Process Table 13B Supervisory Assessment of Fitness" for Waivers vs "Fatigue Assessment" Table 15 Documents, Reports, and Reviews Required under Subpart I Table 16 Work Hour Control Effectiveness Review Process Graphic 1 Fatigue Management as Part of Overall FFD Strategy Graphic 2 Minimum Shift Complement During Outage - From Reg. Guide 5.73

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