New guy here
I'm a Licensed Reactor Operator and have been for more than 10 years. My utility recently implemented the Part 26 rules (waited until damn near the last minute, I know) and a few of us Operators think that some of the Part 26 requirements are being interpreted/used incorrectly as per the actual rule and I'm curious as to how your utilities are implementing this.
My question has to do with how is your utility interpreting what a "shift cycle" actually is? To me, the actual rule is VERY clear. The rule defines a shift cycle as...
"Shift cycle means a series of consecutive work shifts and days off that is planned by the licensee or other entity to repeat regularly, thereby constituting a continuous shift schedule."We have 5 crews, work 12 hour days, and rotate every 5 weeks. A very normal/typical 5 week rotating shift schedule. While it would seem very clear to me that we are on a 5 week
shift cycle, my utility is using a 6 week shift cycle for the purposes of calculating our minimum days off requirements.
I've done a lot of reading on the Part 26 rules and even the examples lead one to believe that if you have 5 crews and rotate every 5 weeks that you are on a 5 week shift cycle. The concern that we are doing this incorrectly has been brought to the attention of management but our fleet Part 26 gurus continue to say that we can use a 6 week shift cycle. Now, I can see how if somebody is on a 1,2,3 or 6 week shift cycle that one could say that a 6 week shift cycle, for the purposes of calculating your minimum days off, is allowed (since those are all multiples of 6 and thus, using a 6 week shift cycle the schedule would repeat continuously as per the definition) but there is no way from the way I read it that a 4 or 5 week schedule could be made into a 6 week "shift cycle" as per the Part 26 rules. There are a number of us right now who are, in our opinions, violating the Part 26 rule because we have less than 2.5 days off per week (averaged) over the 5 week shift cycle but when using 6 weeks we are just above the requirement.
Anyway, I'm curious to hear from those of you who are also on a 5 crew, 5 week schedule if you are using a 5 week shift cycle or a 6 week shift cycle for Part 26 rules? Thanks!