Clarification of Nuclear Power Plant Staff Working Hours

HPPOS-253 PDR-9209210083

See memorandum from L. J. Cunningham to J. H. Joyner (and others) dated September 17, 1992.

The memo provides a clarification of the Technical Specifications (TS's) concerning working hours for nuclear power plant staffs, including HP's. Individual staff members should not work more than 16 straight hours, more than 16 hours in a 24-hour period, more than 24 hours in a 48-hour period, or more than 72 hours in a 7-day period. The 7-day period specified in TS's should be treated as any rolling 7-day period. HPPOS-024 and HPPOS-173 contain related topics.

Standard TS's state that for personnel performing safety related functions "... in the event overtime is to be used, on a temporary basis, the following guidelines shall be followed:

1. An individual should not be permitted to work more than 16 hours straight, excluding shift turnover time.

2. An individual should not be permitted to work more than 16 hours in any 24-hour period, nor more than 24 hours in any 48-hour period, nor more than 72 hours in any 7-day period, all excluding shift turnover time.

3. A break of at least 8 hours should be allowed between work periods, including shift turnover time.

Any deviation from the above guidelines shall be authorized in advance by the Plant Superintendent or his deputy or higher levels of management."

A review of a Regional inspection report and resulting Notice of Violation has suggested that clarification is needed concerning TS's on working hours for nuclear power plant staffs, including HP's. In the reported violation, the 7-day week period was treated by the licensee as a fixed, one-week period, Sunday through Saturday. This allowed the 7-day window to be reset at the end of the week. The 7-day week period specified in TS's should be treated as any rolling 7-day period.

Another concern in the inspection report was what the licensee interpreted as "shift turnover." Shift turnover consists of non-working activities such as casual conversation with fellow employees concerning watch relief, review of shift logs and the changing of clothing (modesty garments into street clothes and vice versa). The Radiation Protection and Operations supervisors misinterpreted this TS and permitted off-going technicians to complete radiological survey maps after shift relief. This time was incorrectly left off the time applied toward the 72-hour TS requirement, which added to the violation.

In addition, other activities, such as individual decontamination, whole-body counting, and decay (e.g., to permit the decay of gaseous radon daughter products), should not normally be considered part of shift turnover time. The time associated with these activities (as well as other related activities to be considered on a case by case basis) should be considered working time towards TS limits. This added time should not cause the individual to have less than 8 hours off between shifts. However, the licensee should not be cited for a violation of the TS limits for permitting the individual to work more than 16 hours straight (as this in not safety related work) as long as a break of at least 8 hours is allowed between work periods.

As an example, a technician worked a double shift of 16 hours and, after being relieved of his duties, was found to be contaminated. After an initial survey, decontamination, re-survey and whole-body count, two hours of additional time elapsed which are not part of normal shift turnover. The technician was not performing technical specification (TS) work during this 2-hour period so the TS that restricts work to 16 hours straight was not violated; however, if the technician reported for his next regular shift he would have been in violation for not having an 8 hour break between work periods. The technicians next shift would have to be modified (pushed back at least two hours). This health physics position was reviewed by the TS Branch for generic applicability and it agrees with the position.

Regulatory references: Technical Specifications

Subject codes: 1.4, 1.5, 1.7

Applicability: Reactors