I just found out something interesting. NRC rule says 60 hours per week averaged over a 6 week period...but my utility is going to 54 hours per week over 6 weeks, to ensure they don't violate the NRC reg.
...and, yes, the rule will apply to contractors.
Ok, as they say...not so much.
The new 10 CFR Part 26 rules apply to
"covered" workers. Who are covered workers? They would be Operators, Security, Maintenance, HP, Chemistry, and Fire Brigade.
Now as for the limitations for HP's, they are only "covered" if they are performing Health Physics duties as
a member of the on-site emergency organization minimum shift complement. Contract HP's are
NOT covered workers. BTW Maintenance folks are covered only if they are working on SSC's (structures, system's, and components), that a risk-informed evaluation process has shown to be significant to public health and safety.
Some utilities are opting for keeping their shift technician rotations intact during outages thus eliminating the number of folks who are subject to both the working hour limitations AND the minimum days off that apply to covered workers. Other utilities are including ALL house techs that fill the role of shift technicians and therefore do run the risk of after an outage having someone run afoul of the working hour limitations since it is a rolling 6 week time frame.
The reason that some utilities are going to a 4 on 1 off 12 hour schedule is to compensate for the minimum days off required. For HP's working a 12 hour shift
OUTAGE schedule they are required to get 3 days off in each successive (non-rolling) 15 day period. This BTWEonly applies to the first 60 days of an outage, then the on-line rules kick in. The working hours, again as applies to "covered" workers are:
16hrs in a 24 hr period
26hrs in a 48 hr period
72hrs in any 168 hr (7day) period
While I understand that there is a lot of confusion, and misinformation, rumors are the worst thing. The LAW does go into affect October 01, 2009, and no it has absolutely nothing to do with unions.
I think it will be interesting to see which union house types decide to grieve this, if the contract HP's work more hours. However, the way I look at it, is it any different when you have all sorts of different schedules for the various folks during an outage?
I have been part of a Working Hour Limitations (WHL) project group setting up the rules and procedures here at my utility, so if you have specific questions, fire 'em up and I'll do my best to get you the straight scoop.
