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Trinian23

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NRC Rule change concerning working hours.
« on: Nov 06, 2005, 09:33 »
Does anyone have any information on the upcoming NRC rule change concerning working hours? Specifically, what the changes will be and any links to help support that. Also, what are other plants planning to do to help implement this rule change?

Fermi2

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Re: NRC Rule change concerning working hours.
« Reply #1 on: Nov 09, 2005, 05:35 »
Does anyone have any information on the upcoming NRC rule change concerning working hours? Specifically, what the changes will be and any links to help support that. Also, what are other plants planning to do to help implement this rule change?

Sorry it took so long.

http://www.nrc.gov/reading-rm/doc-collections/commission/secys/2005/secy2005-0074/2005-0074scy.html


Mike

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Re: NRC Rule change concerning working hours.
« Reply #3 on: Nov 10, 2005, 01:31 »
The new rule doesn't mean much to the worker-bees.  The same restrictions apply almost the same as before.  The limits on work hours are:
No more than; 16 hrs in a 24 hr period, 26 in 48 or 72 in 7 days.  There has to be at least an 8 hour break between shifts.  Turnover time doesn't count.  The rule only applies to certain people.
Workers who are limited by these rules are:
Plant Operators
Security Personnel
Fire Brigade Members
Shift RP and Chemistry Techs
Persons performing maintenance on Safety Related structures, systems or components.

The majority of RP, Chemistry, Decon, and Maintenance personnel will not be affected by the rule because it only applies to people actually engaged in the safety related work.  (i.e. An RP Tech who is qualified to perform as the "Shift Tech"<1> isn't limited unless he is actually assigned to that duty.  Likewise a plant operator who is operating non-safety-related systems isn't limited, and a mechanic working on non-safety-related equipment isn't either.)

The change is more administrative than anything else, although it does require the licensees to go a little further than just hour-tracking to manage worker fatigue.  Recognizing that people are all different, and that some need more rest than others, is a good thing.  Simply limiting work hours to 26/48 or 72/week doesn't address the problem that some workers get tired for other reasons like stress, physical demands of the work, age, health, fitness, or even the repetitive nature of their jobs.  It is unsafe (as well as unfair) to demand that someone work beyond his or her physical limits and then justify it by claiming that the hour limits were not exceeded.  If someone is tired, and especially if they admit that they are tired, they should not be working at a nuclear power plant.  The new rule requires licensees to accept this fact and to be more proactive in managing worker fatigue.
So, the "bottom line" is that you don't have to worry about losing that 7th day's OT when working outages.  Just make sure you get enough sleep.

<1> "Shift Tech" means a technician who is part of the minimum shift complement for emergency response purposes.  Sometimes, this person is referred to as the "E-Plan" Technician or something similar.
« Last Edit: Nov 10, 2005, 01:41 by BeerCourt »
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ageoldtech

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Re: NRC Rule change concerning working hours.
« Reply #4 on: Nov 10, 2005, 08:25 »
BeerCourt, I read the differences between the old and new 10 CFR 26, It was not very clear. How does the 8 week exemption effect outages >8 weeks for worker bees?

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Re: NRC Rule change concerning working hours.
« Reply #5 on: Nov 10, 2005, 06:01 »
I'm still trying to decipher some of the rules.  That thing is almost 900 pages long.  Typical government job - bury the five paragraphs that actually mean something in a trillion word publication.
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shayne

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Re: NRC Rule change concerning working hours.
« Reply #6 on: Nov 10, 2005, 07:41 »
This link is the summary of changes.
http://www.nrc.gov/reading-rm/doc-collections/commission/secys/2005/secy2005-0074/attachment1.pdf

The working hours changes are part of Subpart I
Quote
Subpart I—Managing Fatigue
   Establish program requirements for fatigue management at nuclear power plants.
•   Codify a process for workers to self-declare that they are not fit for duty because of fatigue. (§26.197)
•   Require training for workers and supervisors on symptoms of and contributors to fatigue and on fatigue countermeasures. (§26.197)
•   Require licensees to include fatigue management information in the annual FFD program performance report that would be required under §26.217, including the number of waivers of the individual limits and break requirements that were granted, the collective work hours of any job duty group that exceeded the group average limit in any averaging period, and certain details of fatigue assessments conducted. (§26.197)
   Establish work hour controls for certain job functions at nuclear power plants, performed by operations, maintenance, health physics, chemistry, security and some fire brigade personnel.
•   Establish individual work hour limits of no more than 16 hours in a 24 hour period, 26 hours in a 48 hour period, and 72 hours in a week, excluding shift turnovers. (§26.199)
•   Establish individual break requirements of at least 10 hours between shifts, a 24-hour break in any 7 days, and a 48-hour break in any 2 weeks, with some exceptions for outages. (§26.199)
•   Allow licensees to waive the individual work hour limits and break requirements only if necessary to mitigate or prevent a condition adverse to safety or to maintain the security of the facility and if a fatigue assessment is performed for the worker with satisfactory results. (§26.199)
•   Would not permit licensees to waive the individual work hour limits and break requirements for individuals who self-declare they are unfit due to fatigue; if a fatigue assessment performed for those individuals determined they were fit, the individuals would only be permitted to perform non-risk significant activities under the waiver. (§26.199)
•   Establish a group average limit of 48 hours/week over a 13-week calculation period. (§26.199)
   The first 8 weeks of a plant outage would be exempted from the limit for non-security personnel and would be increased to 60 hours/week for security personnel. (§26.199)
   Security personnel would be allowed a 60 hour/week limit during the first 8 weeks of any planned security system outages. (§26.199)
   Security personnel would not be subject to any group average limit during the first 8 weeks of an unplanned security system outage or increased threat condition. (§26.199)
   Successive plant outages separated by 2 weeks or less would be considered as a single plant outage for purposes of the 8-week exemption. (§26.199)
•   Allow the average work hours of any job duty group to exceed the 48 hour/week limit in one averaging period if either:
   NRC approval is obtained, or
   The circumstances could not be reasonably controlled, the group average does not exceed 54 hours/week, and the additional hours are worked only to address the circumstances the licensee could not have reasonably controlled. The group average would not be allowed to exceed the 48-hour/week limit in any two consecutive averaging periods without NRC approval. (§26.199)
•   Waive the individual and group limits during a declared emergency. (§26.199)
•   Waive the individual and group limits for security personnel if the NRC notifies licensees in writing that the limits are waived in order to assure the common defense and security. (§26.199)
•   Require licensees to review individual and group hours worked, including reviews for any individuals granted more than one waiver, individuals assessed for fatigue, individuals with average work hours over 54 hours/week when subject to a 48 hour/week group average, and individuals with over 66 hours/week when subject to a 60 hour/week group average limit. The rule would require licensees to record, trend, and correct, under the corrective action program, problems found with fatigue management. (§26.199)
   Require face-to-face fatigue assessments for specific post-event, for-cause, self-declaration and follow-up conditions. (§26.201)

I also have some papers that I got from work that have some of the Working Hours Rulemaking efforts from NEI and the Industry, send Me a PM if you want a copy of them.
« Last Edit: Nov 10, 2005, 07:43 by Shayne »

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Re: NRC Rule change concerning working hours.
« Reply #7 on: Nov 10, 2005, 10:37 »
Unless your work group is one of the 5 listed, the effect is nothing.  If you are in one of those groups, the work-group average hour limits take effect after the first 8 weeks of an outage.
Back-to-back outages with less than two weeks in between count as one outage for the 8 week rule.  The interesting question is how this affects a licensee like Entergy or Exelon who have consecutive outages at multiple sites.  Considering the "shared resources" including contractors moving from outage to outage, how will this affect the averages of their respective work groups?  Will they define the work groups who share people as a large single group, or count them independent for each site?  Will the work hours of a person who is being "shared" count against the average at his or her home plant or against the host plant, or both?
Ahh!  Nuthin' like asking simple questions to scramble the collective brains of the powers-that-be.  (Insert a sinister laughing sound here).
« Last Edit: Nov 10, 2005, 11:43 by BeerCourt »
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Fermi2

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Re: NRC Rule change concerning working hours.
« Reply #8 on: Nov 11, 2005, 12:25 »
Not entirely true. This is just the first step, eventually the NRC would like to insert a maximum of a 12 hour work day, with no more than 60 hours in any week with no waivers. Also if you have access to the protected area they'd eventually make it so you you'll fall under the rule.

The people who really get screwed on this whole deal are the plants still on 8 hour shifts.

Mike

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Re: NRC Rule change concerning working hours.
« Reply #9 on: Nov 11, 2005, 02:50 »
Whoa Trigger!  We're still talking about the current new rule.  Future new rules are another matter entirely.
These rules don't usually apply to me anyway.  I'm not an operator, or security guard.  I don't do maintenance on safety related systems, and I haven't been a shift RP since I got sacked from my house tech job seven years ago.
Nobody is going to get "screwed" by the rules.  Plants are just going to have to readjust the way they manage manpower.
"To be content with little is hard; to be content with much, impossible." - Marie von Ebner-Eschenbach

Offline M1Ark

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Re: NRC Rule change concerning working hours.
« Reply #10 on: Nov 11, 2005, 03:50 »
I think the biggest impact for Operations and Security is the 48 hr/week group average per 13 week period.  I'm all for the new rule but the union plants will struggle how to equalize time in the bargaining units.  Interesting how this will play out.  The company I work for is hiring 27 Aux. Operators and 15 SRO's in 2006 to get ahead of this new rule and absorb expected retirements and normal attrition.

Fermi2

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Re: NRC Rule change concerning working hours.
« Reply #11 on: Nov 11, 2005, 04:17 »
What I should have said is when the NRC finally implements THIS rule that's what they want.

I agree the rules won't cost anyone any money.

Hell I'm a manager anyway, if I had my choice I'd be limited to 40 a week, but that ain't happening soon!! :)

M1Ark are you at a plant that's on 8 hour shifts?

Mike

dangrs1

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Re: NRC Rule change concerning working hours.
« Reply #12 on: Dec 01, 2005, 02:55 »
I went to the meeting with the NRC in Morris, Illinois on November 7, 2005.
I asked a lot of questions. If any of you think this is not going affect you you are sadly mistaken. Short of the guy pushing a broom and the managers you will see a huge reduction in your hours. It affects all work groups and contractors going into the plant. The part about safety related only is not true. I asked those questions.
Everyone will only work a maximum of six days a week every other week. During an outage you can do the first two weeks on six days and on the third week you can only work five days. An outage is considered the week before and the week after shut down.
I don't know about the rest of you but I don't want to travel away form home to work five days a week. I did a quick calculation and I stand to lose at least $15k on this years overtime if the rule was in effect.
We have until December 27, 2005 to get our comments on the rule in. This is not a done deal yet. The big thing to remember is that they want to change these rules because they don't think were safe and they believe we are being threatened into working overtime.
I have the notes from the NRC meeting on a pdf file if anyone wants them I can email them. Go to the NRC web site and search for "fatigue" and see what all the anti-nuc's are saying about us.
Comments can be posted anonymously on the web site, emailed to SECY@nrc.gov, faxed to 301-415-1101, or through US mail at U.S. Nuclear Regulatory Commission, Washington, DC 20555-001
Please take the time to do this. Don't assume others are writing. Don't assume this won't affect you. If they don't here from us they will think this is what we want.
Tell everyone you know in the industry that they also need to be heard from.


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Re: NRC Rule change concerning working hours.
« Reply #13 on: Dec 01, 2005, 09:17 »
Here's where we always get into the confusing part - The huge gaping hole between what the rule actually says and what the local NRC guy thinks the rule says.  That's why the old rule was so damned confusing, because every region of the NRC enforces it differently and every licensee uses different procedures to comply.
If anybody wants to make a wager, I'll put my money on the extreme probability that you will be able to work 84 hour weeks at some plants and 50 at others.  I'll make a side bet that every single plant will make exceptions to every one of these rules so that you can work whenever they need you to, but you can't get any OT if they think it will cost them too much $$$$.  Basically nothing will change until the outages go on for 10 or 12 weeks, at which point everyone will go back to working around the clock.
"To be content with little is hard; to be content with much, impossible." - Marie von Ebner-Eschenbach

pappy

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Re: NRC Rule change concerning working hours.
« Reply #14 on: Dec 01, 2005, 11:43 »
Biggest thing I see is that IF the rules/changes are enforced, there physically is not enuff people to go around to support the limited hours. If ops is having to work 750-1000hrs OT to support normal operations because of understaffing, then how can they work less & still operate the plant. Same for some RP staffs. I have seen a couple of plants that barely have e-plan staffing now. Those are hours I have been quoted from ops guys at a few outages I have worked in the last couple of years...... ???

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Re: NRC Rule change concerning working hours.
« Reply #15 on: Dec 02, 2005, 07:37 »
I hope it happens because it will increase the demand for staffing (techs& ops) which will lead to more competition and better pay!!!! After TMI the hours went down and the pay went up so now 25 years later it is time for the cycle to repeat again.

Trinian23

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Re: NRC Rule change concerning working hours.
« Reply #16 on: Dec 02, 2005, 08:18 »
Well,
    I know for us, using the rules that Shayne provided me with from the recent meetings, it would be impossible for us to meet the new rules. (We are under contract for an 8 hour rotation). However, because of said contract, if we had to move to a 12 hour schedule, the OT would be great! (Anything over 8/day, etc) which is already under contact. However, our current management believes that the current 8 hour shift rotation that we have meets the new requirements (which it doesn't). We have a standard 6 crew 8 hour rotation.

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Re: NRC Rule change concerning working hours.
« Reply #17 on: Dec 03, 2005, 09:15 »
Which facility do you work at, Trinian?  I didn't realize there were sites still working 6 crew rotation.  Are there any others working 6 crew rotation?

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Re: NRC Rule change concerning working hours.
« Reply #18 on: Dec 03, 2005, 03:24 »
Which facility do you work at, Trinian?  I didn't realize there were sites still working 6 crew rotation.  Are there any others working 6 crew rotation?

I work 6 crew, but 12 Hour shifts.

Trinian23

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Re: NRC Rule change concerning working hours.
« Reply #19 on: Dec 09, 2005, 01:51 »
I work at Clinton.

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Re: NRC Rule change concerning working hours.
« Reply #20 on: May 20, 2007, 12:40 »
I've talked to a couple higher ups at 2 plants, and I've been reading on the NRC site.  The newest bottom line for HP types and some others seems to be 3 days off for every 15 days (for less than 60 day outages I believe).  Does this mean you can work a 72 hour week one week and then a 60 hour week the next?  I've also been told that it won't be put in to place for 12-18 months. 

It's hard to make out what they are really talking about due to the legal-ease-ish way everything is written, and it is written a different way in different parts of the nrc website.

Anybody who is better at wading thru this crap care to give me a better bottom line?  I've been reading very recent stuff on the NRC website that just got "voted on", however that works....

LaFeet

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Re: NRC Rule change concerning working hours.
« Reply #21 on: May 20, 2007, 10:12 »
Hey Hammie.... I still be doing my usual here.  No recoil as of yet, heck my boss just did 21 and then came in the same night for another 12.  Remember, the pen motion is all in the wrist.

Offline Mike McFarlin

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Re: NRC Rule change concerning working hours.
« Reply #22 on: May 22, 2007, 03:09 »
Its all schedule driven.
"Duty is the sublimest word in our language. Do your duty in all things. You cannot do more. You should never wish to do less." General Robert E. Lee, C.S.A.

LaFeet

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Re: NRC Rule change concerning working hours.
« Reply #23 on: May 22, 2007, 05:26 »
Aint that the truth.  Heck, I dont mind a few extra dollars every now and then.  Keeps me from having to work all year long.

illegalsmile

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Re: NRC Rule change concerning working hours.
« Reply #24 on: May 22, 2007, 07:14 »
from what I could see, the rule isn't going to effect the 'tech-in-the-trenches.' The most they'd have to do is pen-stroke us into and exemption or variance or whatever term they wind up applying.
The more things change ....

 


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