U.S. Nuclear Regulatory Commission

Clarification of Nuclear Power Plant Staff Working Hours

HPPOS-253 PDR-9209210083

Title: Clarification of Nuclear Power Plant Staff Working

Hours

See memorandum from L. J. Cunningham to J. H. Joyner (and

others) dated September 17, 1992. The memo provides a

clarification of the Technical Specifications (TS's)

concerning working hours for nuclear power plant staffs,

including HP's. Individual staff members should not work

more than 16 straight hours, more than 16 hours in a

24-hour period, more than 24 hours in a 48-hour period, or

more than 72 hours in a 7-day period. The 7-day period

specified in TS's should be treated as any rolling 7-day

period. HPPOS-024 and HPPOS-173 contain related topics.

Standard TS's state that for personnel performing safety

related functions "... in the event overtime is to be used,

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.

Any deviation from the above guidelines shall be authorized

in advance by the Plant Superintendent or his deputy or

higher levels of management."

A review of a Regional inspection report and resulting

Notice of Violation has suggested that clarification is

needed concerning TS's on working hours for nuclear power

plant staffs, including HP's. In the reported violation,

the 7-day week period was treated by the licensee as a

fixed, one-week period, Sunday through Saturday. This

allowed the 7-day window to be reset at the end of the

week. The 7-day week period specified in TS's should be

treated as any rolling 7-day period.

Another concern in the inspection report was what the

licensee interpreted as "shift turnover." Shift turnover

consists of non-working activities such as casual

conversation with fellow employees concerning watch relief,

review of shift logs and the changing of clothing (modesty

garments into street clothes and vice versa). The

Radiation Protection and Operations supervisors

misinterpreted this TS and permitted off-going technicians

to complete radiological survey maps after shift relief.

This time was incorrectly left off the time applied toward

the 72-hour TS requirement, which added to the violation.

In addition, other activities, such as individual

decontamination, whole-body counting, and decay (e.g., to

permit the decay of gaseous radon daughter products),

should not normally be considered part of shift turnover

time. The time associated with these activities (as well

as other related activities to be considered on a case by

case basis) should be considered working time towards TS

limits. This added time should not cause the individual to

have less than 8 hours off between shifts. However, the

licensee should not be cited for a violation of the TS

limits for permitting the individual to work more than 16

hours straight (as this in not safety related work) as long

as a break of at least 8 hours is allowed between work

periods.

As an example, a technician worked a double shift of 16

hours and, after being relieved of his duties, was found to

be contaminated. After an initial survey, decontamination,

re-survey and whole-body count, two hours of additional

time elapsed which are not part of normal shift turnover.

The technician was not performing technical specification

(TS) work during this 2-hour period so the TS that

restricts work to 16 hours straight was not violated;

however, if the technician reported for his next regular

shift he would have been in violation for not having an 8

hour break between work periods. The technicians next

shift would have to be modified (pushed back at least two

hours). This health physics position was reviewed by the

TS Branch for generic applicability and it agrees with the

position.

Regulatory references: Technical Specifications

Subject codes: 1.4, 1.5, 1.7

Applicability: Reactors