Re: Hourly labor restrictions for nuclear workers

[Judd Sills <sillsj@GAT.COM>]

At 03:26 PM 8/12/97 -0500, you wrote:
>     I am trying to find if 10 CFR contains any regulations on how long 
>     personnel can work in a nuclear safety capacity.  I have some numbers, 
>     but cannot find the regulatory reference.  The numbers I have are:
>     
>     No more than 13 consecutive hours
>     No more than 72 hours in any consecutive 7 day period
>     No more than 24 hours in any consecutive 48 hour period
>     No more than 16 hours in any consecutive 24 hours period
>     
>     I have a possible reference of a NRC Guidance Letter 8212.
>     
>     Can anybody help match these restrictions to a 10 CFR or other 
>     regulatory document?
>     
>     Send responses to DEAN.STEWART@RFETS.GOV
>
This is generally addressed in the Administrative Controls section of
the Technical Specifications for nuclear power plants, and is germaine
to workers in defined safety related functions.  There is nothing in the
CFR that addresses this issue for the industry as a whole, to the best of
my awareness.  I have copied an example of such admin controls below from
the CE Improved Standard Technical Specifications (NUREG-1432).  The 
wording is different than plants with the older Tech Spec format, but the 
intent is the same.  Generic Letter 82-12 issued the requirements for these
controls, and may be seen in its entirety at 
ftp://ftp.fedworld.gov/pub/nrc-gc/gl82012.txt
Excerpts from the GL 82-12 are also provided to help out.

Best regards
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Excerpt NUREG-1432
"5.2.2.e
Administrative procedures shall be developed and implemented to limit the 
working hours of unit staff who perform safety related functions (e.g., 
licensed SROs, licensed ROs, health physicists, auxiliary operators, and 
key maintenance personnel).

		Adequate shift coverage shall be maintained without routine heavy 
use of overtime.  The objective shall be to have operating personnel work
an [8 or 
12] hour day, nominal 40 hour week while the unit 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 modification, 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;

                 4.   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.

		Any deviation from the above guidelines shall be authorized in 
advance by the [Plant Superintendent] or his designee, in accordance with
approved 
administrative procedures, or by higher levels of management, in accordance
with 
established procedures and with documentation of the basis for granting the
deviation.

		Controls shall be included in the procedures such that individual 
overtime shall be reviewed monthly by the [Plant Superintendent] or his
designee to 
ensure that excessive hours have not been assigned.  Routine deviation from
the above 
guidelines is not authorized.

		OR
	
		The amount of overtime worked by unit staff members performing safety 
related functions shall be limited and controlled in accordance with the
NRC Policy 
Statement on working hours (Generic Letter 82-12).

============================================================================
========
Excerpts from GL 82-12

"                               June 15, 1982 



TO ALL LICENSEES OF OPERATING PLANTS, APPLICANTS FOR AN OPERATING LICENSE, 

AND HOLDERS OF CONSTRUCTION PERMITS "
..................

"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."
========================================================================
Judd M. Sills, CHP           |   Office: (619)455-2049
General Atomics, Room 01-166C|      Fax: (619)455-3181
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