Nuclear Power Plant Staff Working Hours (Generic Letter No. 82-12)

                               UNITED STATES 
                       NUCLEAR REGULATORY COMMISSION 
                           WASHINGTON D. C. 20555 

                               June 15, 1982 

TO ALL LICENSEES OF OPERATING PLANTS, APPLICANTS FOR AN OPERATING LICENSE, 
AND HOLDERS OF CONSTRUCTION PERMITS 

Gentlemen: 

SUBJECT:  NUCLEAR POWER PLANT STAFF WORKING HOURS 
          (Generic Letter No. 82-12) 

On February 8, 1982, we forwarded to you a copy of a policy statement issued
by the Commission entitled "Policy on Factors Causing Fatigue of Operating 
Personnel at Nuclear Reactors." That policy statement has now been slightly 
revised and the revised version is attached to this letter. The forwarding 
letter (Generic Letter 82-02) stated that actions were underway to 
incorporate the Commission policy on working hours into Regulatory Guide 
1.33 and into NUREG-0737 (Item I.A.1.3). 

Publication of Regulatory Guide 1.33 is now anticipated in June 1982, 
following release of ANS 3.2. Revised pages of NUREG-0737 that incorporate 
the Commission policy on working hours are enclosed. 

Our letter of February 8, 1982 requested that you take action as necessary 
to revise the administrative section of your technical specifications to 
assure that your plant administrative procedures follow the revised working 
hour guidelines, including a provision for documentation of authorized 
deviations which should be available for NRC review. You should review your 
past actions to assure that they are consistent with the attached revised 
policy statement. Note that the revised guidelines are to be incorporated by
October 1, 1982. 

                              Sincerely, 


                              Darrell G. Eisenhut, Director  
                              Division of Licensing  
                              Office of Nuclear Reactor Regulation 

Attachment: 
Revision to Item I.A.1.3 
  of NUREG-0737 




8206160341 
.
I.A.1.3 SHIFT MANNING 

Pages I.A.1.3-1 through I.A.1.3-3 are replaced in their entirety by the 
following. A bar in the margin indicates changes from the material 
originally included on these pages. 

Position 

This position defines shift manning requirements for normal operation. The 
letter of July 31, 1980 from D. G. Eisenhut to all power reactor licensees 
and applicants (copy attached) sets forth the interim criteria for shift 
staffing (to be effective pending general criteria that will be the subject 
of future rulemaking). Overtime restrictions were also included in the July 
31, 1980 letter. 

Changes to Previous Requirements and Guidance 

Errors were discovered in the last column of the table attached to the 
letter of July 31, 1980. A corrected table is enclosed; a bar in the margin 
indicates the correction. (See p. I.A.1.3-4.) 

The overtime requirements have been rewritten to incorporate the provisions 
of a Commission policy statement on working hours and operator fatigue. 

Clarification 

Licensees of operating plants and applicants for operating licenses shall 
include in their administrative procedures (required by license conditions) 
provisions governing required shift staffing and movement of key individuals
about the plant. These provisions are required to assure that qualified 
plant personnel to man the operational shifts are readily available in the 
event of an abnormal or emergency situation. 
.

                                     - 2 - 

These administrative procedures shall also set forth a policy, the objective
of which is to prevent situations where fatigue could reduce the ability of 
operating personnel to keep the reactor in a safe condition. The controls 
established should assure that, to the extent practicable, personnel are not
assigned to shift duties while in a fatigued condition that could 
significantly reduce their mental alertness or their decision making 
ability. The controls shall apply to the plant staff who perform 
safety-related functions (e.g., senior reactor operators, reactor operators, 
auxiliary operators, health physicists, and key maintenance personnel). 

IE Circular No. 80-02, "Nuclear Power Plant Staff Work Hours", dated 
February 1, 1980 (copy attached) discusses the concern of overtime work for 
members of the plant staff who perform safety-related functions. The 
guidance contained in IE Circular No. 80-02 was amended by the July 31, 1980 
letter. In turn, the overtime guidance of the July 31, 1980 letter was 
revised in Section I.A.1.3 of NUREG-0737. The NRC has issued a policy 
statement (attached) which further revises the overtime guidance as stated 
in NUREG-0737. This guidance is as follows: 

Enough plant operating personnel should be employed to maintain adequate 
shift coverage without routine heavy use of overtime. The objective is to 
have operating personnel work a normal 8-hour day, 40-hour week while the 
plant is operating. However, in the event that unforeseen problems require 
substantial amounts of overtime to be used, or during extended periods of 
shutdown for refueling, major maintenance or major plant modifications, on a 
temporary basis, the following guidelines shall be followed: 
.

                                    - 3 - 

a.   An individual should not be permitted to work more than 16 hours 
     straight (excluding shift turnover time). 

b.   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 seven day period (all excluding shift turnover 
     time). 

c.   A break of at least eight hours should be allowed between work periods 
     (including shift turnover time). 

d.   Except during extended shutdown periods, the use of overtime should be 
     considered on an individual basis and not for the entire staff on 
     shift. 

Recognizing that very unusual circumstances may arise requiring deviation 
from the above guidelines, such deviation shall be authorized by the plant 
manager or his deputy, or higher levels of management. The paramount 
consideration in such authorization shall be that significant reductions in 
the effectiveness of operating personnel would be highly unlikely. 
Authorized deviations to the working hour guidelines shall be documented and 
available for NRC review. 

In addition, procedures are encouraged that would allow licensed operators 
at the controls to be periodically relieved and assigned to other duties 
away from the control board during their tours of duty. 

Operating license applicants shall complete these administrative procedures 
before fuel loading. Development and implementation of the administrative 
procedures at operating plants will be reviewed by the Office of Inspection 
and Enforcement beginning Oct. 1, 1982. 
.

                                    - 4 -  

See Section III.A.1.2 for minimum staffing and augment capabilities for 
emergencies. 

Applicability 

This requirement applies to all licensees of operating reactors and 
applicants for operating licenses. 

Implementation 

(1)  Overtime administrative procedures shall be established for operating 
     reactors by Oct. 1, 1982 and by fuel loading for applicants for 
     operating license. 

(2)  Staffing requirements shall be completed by July 1, 1982 for operating 
     reactors and by fuel load for operating license applicants. 

Type of Review 

A post-implementation review will be performed on operating reactors. 
Applicants for operating licenses will be reviewed prior to implementation. 

Documentation Required 

The documentation required is as noted in the letter of July 31, 1980. 

Technical Specification Changes Required 

Changes to Technical Specifications will be required for overtime 
administrative procedure and staffing requirements. 
.

                                    - 5 - 

References 

NUREG-0660 

IE Circular No. 80-02, "Nuclear Power Plant Staff Work Hours," February 1, 
1980 Letter from D. G. Eisenhut, NRC, to All Power Reactor Licensees, July 
31, 1980 Policy on Factors Causing Fatigue of Operating Personnel at Nuclear
Reactors,  
.

              POLICY ON FACTORS CAUSING FATIGUE OF OPERATING 
                      PERSONNEL AT NUCLEAR REACTORS 

Licensees of operating plants and applicants for operating licenses shall 
establish controls to prevent situations where fatigue could reduce the 
ability of operating personnel to keep the reactor in a safe condition. The 
controls should focus on shift staffing and the use of overtime--key 
job-related factors that influence fatigue. 

The objective of the controls would be to assure that, to the extent 
practicable, personnel are not assigned to shift duties while in a fatigued 
condition that could significantly reduce their mental alertness or their 
decision making capability. The controls shall apply to the plant staff who 
perform safety-related functions (e.g., senior reactor operators, reactor 
operators, health physicists, auxiliary operators, and key maintenance 
personnel). 

Enough plant operating personnel should be employed to maintain adequate 
shift coverage without routine heavy use of overtime. The objective is to 
have operating personnel work a normal 8-hour day, 40-hour week while the 
plant is operating. However, in the event that unforeseen problems require 
substantial amounts of overtime to be used, or during extended periods of 
shutdown for refueling, major maintenance or major plant modifications, on a 
temporary basis, the following guidelines shall be followed: 

a.   An individual should not be permitted to work more than 16 hours 
     straight (excluding shift turnover time). 

b.   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 seven day period (all excluding shift turnover 
     time). 

c.   A break of at least eight hours should be allowed between work periods 
     (including shift turnover time). 

d.   Except during extended shutdown periods, the use of overtime should be 
     considered on an individual basis and not for the entire staff on a 
     shift. 

Recognizing that very unusual circumstances may arise requiring deviation 
from the above guidelines, such deviation shall be authorized by the plant 
manager or his deputy, or higher levels of management. The paramount 
consideration in such authorization shall be that significant reductions in 
the effectiveness of operating personnel would be highly unlikely.  

In addition, procedures are encouraged that would allow licensed operators 
controls to be periodically relieved and assigned to other duties away from 
control board during their tour of duty.