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