Issue 133: Update Policy Statement on Nuclear Plant Staff Working Hours

DESCRIPTION

Historical Background

In IE Circular No. 80-02,[1]the concern of overtime work for licensee staff who perform safety-related functions

was discussed and limits on maximum working hours were recommended. In July 1980, a letter[2]was issued to OLs and CPs with interim criteria for shift staffing, including restrictions on overtime. These criteria were

superseded by the NRC requirements issued in NUREG-0737,[3]Item I.A.1.3.

In February NRC issued a policy statement[4]on "Nuclear Power Plant Staff Working Hours." Based on public

comments, this policy statement was revised and reissued[5]in June 1982. Generic Letter 82-12[6]transmitted this latter version of the policy statement to OLs and along with instructions to revise TS administrative procedures to conform to the policy statement. Guidance on incorporating limits on overtime into the TS was

issued in Generic Letters 82-16[7]and 83-02[8]to PWRs and BWRs, respectively. In March 1983, Generic Letter 83-14[9]was issued to clarify the definition of "Key Maintenance Personnel" stated in Generic Letter 82-12. In September 1985, the staff was directed[10]to update the policy statement on "Nuclear Power Plant

Staff Working Hours." Since the NRC policy was stated in several documents, revision of NRC's policy guidance on limits on over me and shift scheduling was needed to consolidate the guidance into a single document.

The existing policy statement and implementing documents were considered adequate from a safety perspective in that the amount of overtime worked by nuclear power plant personnel was not identified as an actual contributor to reportable events, nor did it degrade the safety of plant operations. However, one specific area

of guidance relating to the use of 12-hour shifts was absent from the policy statement. The staff reviewed and approved on a case-by-case basis licensee programs for routine 12-hour shifts (e.g., Oconee and Callaway).

The proposed policy statement was intended to achieve the following: (1) update and clarify NRC's policy on shift scheduling for both routine 8-hour and 12-hour shifts; (2) establish control of overtime hours worked by nuclear power plant personnel who perform safety-related functions; and (3) clarify what action NRC will take in instances where it is determined that fatigue from excessive working hours has degraded personnel performance and thereby contributed to unsafe nuclear power plant operation.

The proposed policy statement was unchanged from existing practice, with respect to administrative procedures, to prevent personnel who perform safety-related functions from working in a fatigued condition during normal operations no more than 16 hours in a 24-hour period, 24 hours in a 48-hour period, or 72 hours in any 7-day period. Overtime on an individual basis was to be controlled with management approval of deviations from recommended limits on working hours.

The staff believed that a revised policy statement on shift and scheduling and hours of work would eliminate licensee confusion resulting from multiple policy and requirement documents and would clearly identify licensee management's responsibility to assure that nuclear power plant staff fatigue resulting from excessive working hours did not adversely affect public health or safety. Additionally, the revied policy statement would benefit the NRC staff in conducting reviews of licensee programs and in monitoring licensee implementation.

CONCLUSION

This issue was classified as a Licensing Issue that was resolved[11]with the issuance of NRC Information Notice No. 91-36.[12]