NEI Fatigue Management

NEI 06-11 [Revision 1]
Managing Personnel
Fatigue at Nuclear Power
Reactor Sites
October 2008
NEI 06-11 [Revision 1]
Nuclear Energy Institute
Managing Personnel
Fatigue at Nuclear Power
Reactor Sites
October 2008
NuclearEnergy Institute, 17761 Street N. W., Suite 400, Washington D.C. (202. 739.8000)
ACKNOWLEDGEM ENTS
This document, Managing Personnel Fatigue at Power Reactor Sites, NEI 06-11, was
developed by members of the NEI Work Hours Task Force. These industry professionals,
experts on access authorization programs, drawing upon practical lessons learned during
the application of the previous requirements, provided valuable insights to update the
program. The changes provide a more efficient and effective program. NEI also wishes to
acknowledge the extensive review and comment by those industry representatives who
shaped the final form of this document:
Joseph Bauer Exelon

Greg Boerschig Exelon
April Brockson Southern Nuclear
Greg Halnon First Energy
John Fee SCE
Peter Fowler Duke Energy Nuclear, LLC
James Gallman Luminant
Mark Giacini Constellation Energy.
James Kammer Duke Energy
Ted Koser STARS
Dave Kulisek TVA
Brian McCabe Progress
Dana Millar Entergy
Billie Rooks Southern Nuclear
Jack Roe NEI
Dave Shafer AmerenUE (Callaway) STARS
Terry Silverberg NMC
Diana Sorfleet Exelon
Jamie Seitz NMC
Ted Vogt SCE
Thomas Wallace TVA
Robert Waselus South Carolina Electric and Gas
James Wicks AEP
David Ziebell EPRI
NOTICE
Neither NET, nor any of its employees, members, supporting organizations, contractors, or
consultants make any warranty, expressed or implied, or assume any legal responsibility for the
accuracy or completeness of, or assume any liability for damages resulting from any use of, any
information apparatus, methods, or process disclosed in this report or that such may not
infringe privately owned rights.
NEI 06-11 (Revision 1)
October 2008
EXECUTIVE SUMMARY
This document provides guidance for managing fatigue in accordance with 10 CFR 26,
Subpart I, ManagingPersonnelFatigue.The goals of this guide are to provide the tools
needed to meet regulatory requirements while:
Maintaining reasonable assurance of industrial and nuclear safety

* Recognizing that a wide variety of work situations exist across the industry
* Supporting management flexibility and decision making when unplanned work is
required
* Providing the records needed to allow the required performance evaluations to be
performed efficiently
* Clarifying the rights and responsibilities of licensees and workers
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TABLE OF CONTENTS
1 INTRODUCTION .......................................................................................................... 1
2 PURPOSE AND APPLICABILITY ...................................... 2
2.1 PURPOSE ..................................................................................................................... 2

2.2 APPLICABILITY ........................................................................................................... 2
3 DEFINITIONS ............... I.............................................................................................. 4
4 IM PLEM ENTATION ..................................................................................................... 8
5 POLICY AND PROCEDURES .................................................................................. 9
5.1 POLICY 9
5.2 PROCEDURES.. ................................................................................................................ 9
6 INDIVIDUALS SUBJECT TO FATIGUE MANAGEMENT AND WORK HOUR
CONTROLS ............................................................................................................... 12
6.1 INDIVIDUALS SUBJECT TO FATIGUE MANAGEMENT ................................................... 12

6.2 WORK HOUR CONTROLS FOR COVERED INDIVIDUALS ........................................... 12
6.3 DIRECTING .............................................................................................................. 13
7 W ORK HOURS SCHEDULING .................................................................................. 18
7.1 PERIODIC O VERTIME ............................................................................................... 19

7.2 TRANSITIONS BETW EEN SCHEDULES ...................................................................... 19
7.3 TRANSITIONING ONTO A SHIFT OR BETWEEN COVERED GROUPS OR INTO A COVERED
GROUP 20
7.4 UNEXPECTED O UTAGES ........................................................................................... 22
7.5 RESET FROM DEVIATIONS ...................................................................................... 23
8 MANAGING HOURS WORKED ............................................................................ 24
8.1 CALCULATING H OURS W ORKED ................................................................................. 24

8.2 WORK HOUR CONTROLS DURING NON-OUTAGE PERIODS .................................... 32
8.3 WORK HOUR CONTROLS DURING OUTAGES, SECURITY SYSTEM OUTAGES, OR
INCREASED THREAT CONDITIONS .......................................................................... 33
9 WAIVERS ................................................................................................................. 40
10 PERSONNEL ACTIONS ......................................................................................... 42
11 EXCEPTIONS ........................................................................................................... 43
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12 FATIGUE ASSESSMENTS................ ............................ 44
12.1 CONDITIONS FOR CONDUCTING FATIGUE ASSESSMENTS ......................................... 44

12.2 INDIVIDUALS CONDUCTING FATIGUE ASSESSMENTS .................................................. 45
12.3 REQUIRED INFORMATION ........................................................................................ 45
12.4 ASSESSMENT AND ACTIONS .................................................................................... 46
12.5 DOCUMENTATION ......................................................................................................... 46
12.6 ASSESSMENT PROCESS ............................................................................................. 47
13 SELF-DECLARATIONS ......................................................................................... 48
14 TRAINING AND EXAM INATION ............................................................................ 49
15 REVIEW S ............................................................... I............................................ 50
16 RECORDS ................................................................................................................ 52
17 REPORTING ............................................................................................................. 53
18 AUDITS ..................................................................................................................... 54
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MANAGING PERSONNEL FATIGUE AT NUCLEAR POWER

REACTOR SITES
1 INTRODUCTION
Reference: 10 CFR Part 26, Subpart I
This guide provides an approach to meeting 10 CFR Part 26, Subpart I requirements related to
managing personnel fatigue at power reactor sites. The management of fatigue is integrated into
the industry's fitness-for-duty program and is addressed in NEI 06-11, Managing Personnel
Fatigue at Nuclear Power Reactor Sites, NEI 03-01, Nuclear Power Plant Access Authorization
Program and NEI 03-04, Guideline for Plant Access Training.
An individual's ability to safely and competently perform his or her duties is not solely based on
the individual's hours worked or that the individual has had adequate rest. Fatigue can be caused
by numerous things including such things as long hours of work, inadequate rest between work
periods, sleep disorders, sedentary lifestyles, work problems or dissatisfaction, home finances
and relationships, inadequate nutrition, emotional stress, physical stress, prescription drugs, and
mental or physical illness. Fatigue may lead to decreased alertness. When an individual is alert,
he or she may be more focused and better able to pay attention. Fatigue and decreased alertness
can substantively degrade an individual's ability to safely and competently perform his or her
duties. Fatigue management is part of the licensee's overall fitness-for-duty (FFD) program.
In 1982 the Nuclear Regulatory Commission issued Generic Letter 82-12, Nuclear Power Plant
Staff Working Hours, providing guidelines for managing the hours worked for individuals
performing safety related work. The current rule was driven, in part, by the variation in
approaches used across the industry to meet these guidelines. To meet the requirements in
Subpart I a detailed process is needed for managing and documenting hours worked.
This guide addresses a number of challenges on the level of detail needed in the program.
This guide addresses the training and the comprehensive examination that is required by Part 26
for the following new knowledge and abilities (KAs):
" Knowledge of the contributors to worker fatigue, circadian variations in alertness and
performance, indications and risk factors for common sleep disorders, shift work
strategies for obtaining adequate rest, and the effective use of fatigue countermeasures
* Ability to identify symptoms of worker fatigue and contributors to decreased alertness in
the workplace.
The training for other KAs associated with FFD is addressed in NEI 03-01 and NEI 03-04.
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2 PURPOSE AND APPLICABILITY
Reference: . 10 CFR Part 26.20 1, "Applicability"
2.1 PURPOSE
The purpose of this guide is to provide the guidance needed by licensees to have an effective
program for meeting the requirements of 10 CFR Part 26 Subpart I related to managing
personnel fatigue. The goal is to provide management processes, record keeping processes and
monitoring tools that ensure compliance while providing guidance for flexibility for day-to-day
operations.
2.2 APPLICABILITY
This guide applies to licensees who are authorized to operate a nuclear power reactor (under Sec.
50.57).
Applicability to licensees who are transitioning from new plant construction to operations will be
addressed in a future.revision.
This guide does not apply to decommissioned plants, not authorized to operate.
2.2.1 Fatigue Management Program, With the Exception of Work Hour Controls
In accordance with 10 CFR 26.4, fatigue management requirements, with exception of work hour
controls, apply to:
* All persons who are granted unescorted access to nuclear power reactor protected areas,
and
* All persons who are required to physically report to the Technical Support Center or
Emergency Operations Facility, in accordance with the site Emergency Plan and
procedures.
Therefore, the Fatigue Management Program, with the exception of Work Hour Controls, shall
be implemented by licensees who are authorized to operate a nuclear power reactor under 10
CFR 50.57, and holders of a combined license under 10 CFR part 52 after the Commission has
made the finding under 10 CFR 52.103(g).
2.2.2 Work Hour Controls for Covered Individuals
10 CFR 26.205, "Work Hours" apply to covered individuals (a subset of the individuals to which
the Fatigue Management Program applies) who are granted unescorted access to nuclear power
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reactor protected areas. Any individual on-site who performs duties within any of the following
job categories is a covered individual subject to work hour controls:
" Operating or on-site directing of the operation of systems and components that a risk-
informed evaluation process has shown to be significant to public health and safety.
" Performing maintenance or on-site directing of the maintenance of structures, systems,
and components (SSCs) that a risk-informed evaluation process has shown to be
significant to public health and safety.
* Performing Health Physics or Chemistry duties required as a member of the on-site
emergency response organization minimum shift complement.
* Performing the duties of a Fire Brigade member who is responsible for understanding the
effects of fire and fire suppressants on safe shutdown capability. The person specifically
designated for understanding the effects of fire and fire suppressants on safe shutdown
capability is considered the person responsible for understanding the effects of fire and
fire suppressants on safe shutdown capability. The remaining Fire Brigade members are
not considered as the person(s) responsible for understanding the effects of fire and fire
suppressants on safe shutdown capability.
* Performing security duties as an armed security force officer, alarm station operator,
response team leader, or watchperson, hereinafter referred to as security personnel.
Implementation of work hour controls for covered individuals for licensees transitioning from
new construction to operations will be addressed in a future revision.
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3 - DEFINITIONS
Reference: 10 CFR Part 26.5
The following definitions are used in this guide.
Acute fatigue means fatigue from causes (e.g., restricted sleep, sustained wakefulness, task
demands) occurring within the past 24 hours.
Alertness means the ability to remain awake and sustain attention.
Break is defined as an interval of time that falls between successive work periods, during which
the individual does not perform any duties for the licensee other than one period of shift turnover
at either the beginning or end of a shift but not both. This means that one period of shift turnover
can be considered as part of the break.
Call-in means returning to the site when not normally scheduled for work.
Circadian variation in alertness and performance means the increases and decreases in
alertness and cognitive/motor functioning caused by human physiological processes (e.g., body
temperature, release of hormones) that vary on an approximately 24-hour cycle.
Contractor/vendor (C/V) means any company, or any individual not employed by a licensee
who is providing work or services to a licensee, either by contract, purchase order, oral
agreement, or other arrangement.
Covered individual means an individual subject to work hour controls. Any individual granted
unescorted access to a nuclear power plant's protected area that performs covered work.
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Covered work means the following:
" Operating or on-site directing of the operation of systems and components that a risk-
informed evaluation process has shown to be significant to public health and safety;
" Performing maintenance or on-site directing of the maintenance of structures, systems,
significant to public health and safety;
emergency response organization minimum shift complement;
* Performing the duties of a Fire Brigade member who is responsible for understanding the
effects of fire and fire suppressants on safe shutdown capability; and
* Performing security duties as an armed security force officer, alarm station operator,
response team leader, or watchperson, hereinafter referred to as security personnel.
Cumulative fatigue means the increase in fatigue over consecutive sleep-wake periods resulting
from inadequate rest.
Day-off means a calendar day in which an individual does not start a work shift.
Deviation means a departure from the requirements included in 10 CFR Part 26 Subpart I.
Directing means the exercise of control over a work activity by an individual who is directly
involved in the execution of the work activity, and either makes technical decisions for that
activity without subsequent technical review, or is ultimately responsible for the correct
performance of that work activity.
Eight (8) -hour shift schedule means a schedule that averages not more than 9 hours per
workday over the entire shift cycle.
Fatigue means the degradation in an individual's cognitive and motor functioning resulting from
inadequate rest.
Incidental duties means those work activities, required by the licensee, performed off-site.
Increased threat condition means an increase in protective measure level, relative to the lowest
protective measure level applicable to the site during the previous 60 days, as promulgated by an
NRC advisory.
On-site means within the owner controlled area of the nuclear power plant.
Off-site means any area not considered on-site.
Maintenance means, the following onsite maintenance activities: Modification, surveillance,

post-maintenance testing, and corrective and preventive maintenance of SSCs that a risk-
informed evaluation process has shown to be significant to public health and safety
Nap or Restorative Sleep means a brief opportunity and accommodations for restorative,
uninterrupted sleep of at least one half hour in a designated area.
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Nominal means the limited flexibility that is permitted in meeting a scheduled due date for
completing a recurrent activity that is required under 10 CFR 26, such as the nominal 12-month
frequency required for FFD refresher training. Completing a recurrent activity at a nominal
frequency means that the activity may be completed within a period that is 25 percent longer or
shorter than the period required in 10 CFR 26. The next scheduled due date would be no later
than the current scheduled due date plus the required frequency for completing the activity.
Protected area means an area encompassed by physical barriers and to which access is
controlled.
Risk informed evaluation process means an evaluation based on a probabilistic risk analyses
approach such as the Maintenance Rule (50.65(a)(4)) or other similar process.
Security personnel means armed security force officer, alarm station operator, response team
leader, or watchperson.
Shift cycle means a series of consecutive work shifts and days off that is planned by the licensee
to repeat regularly, thereby constituting a continuous shift schedule. A shift cycle cannot exceed
6 weeks for the purposes of calculating days off.
Shift turnover means only those activities that are necessary to safely transfer information and
responsibilities between two or more individuals between shifts. Shift turnover activities may
include, but are not limited to, discussions of the status of plant equipment, and the status of
ongoing activities, such as extended tests of safety systems and components.
Tactical exercise means a force-on-force simulation used to evaluate and demonstrate the
capability to defend target sets against selected attributes and characteristics of an adversary. A
force-on-force tactical exercise includes all key program elements of a station's protective
strategy.
Ten (10)-hour shift schedule means a schedule that averages more than 9 hours, but not more
than 11 hours, per workday over the entire shift cycle.
Twelve (12)-hour shift schedule means a schedule that averages more than 11 hours, but not
more than 12 hours, per workday over the entire shift cycle.
Unit outage means that the reactor unit is disconnected from the electrical grid.
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Work hours mean the amount of time an individual performs duties for the licensee. This
includes all work hours, with the following exceptions:
" sShift turnover time.

* Within-shift break and rest periods in which there is reasonable opportunity and
accommodations for restorative sleep (e.g., a nap) may be excluded.
* Unscheduled work hours for the purpose of participating in unannounced emergency
preparedness exercises and drills may be excluded.
NOTE: For the purposes of incidental duties, these times are cumulative. The cumulative 30
minutes is over any calendar day and impacts the break period where the 30 minute limit is
exceeded.
* Incidental duties performed off-site provided the total duration of the work does not
exceed a nominal 30 minutes during any single break period may be excluded.
" For security personnel during the actual conduct of force-on-force tactical exercises
evaluated by the NRC, if security personnel work on their day off, this work day may be
counted as a day off in the calculation of minimum days off.
" For security personnel, during periods defined in writing by the NRC when security
personnel are required to work to ensure the common defense and security.
* Personal time in which an individual is on-site but is off duty (i.e., before or after his/her
normally scheduled work period in which work activities are performed for the licensee)
may be excluded. The individual may be reading the paper, in the on-site fitness center,
eating breakfast, etc.
Work hour controls mean the regulatory requirements in 10 CFR 26.205.
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4 IMPLEMENTATION
The guidance in this document shall be implemented no later than September 30, 2009.
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5 POLICY AND PROCEDURES
Reference: 10 CFR Part 26.203 General Provisions
5.1 POLICY
The licensee shall establish a policy for the management of fatigue for all individuals who are
subject to the licensee's Fitness-For-Duty (FFD) program and incorporate the guidance into the
site or corporate written FFD policy as required in § 26.27(b), FFD Policy. As related to fatigue
management, the FFD policy should:
1. Address the affect of fatigue on FFD;

2. Provide a description of any program that is available to individuals who are seeking
assistance in dealing with fatigue or other problems that could adversely affect an
individual's ability to safely and competently perform the duties that require an
individual to be subject to this subpart;
3. Describe the consequences of violating the policy;
4. Describe the responsibilities of managers, supervisors, and escorts to report FFD
concerns; and
5. Describe the individual's responsibility to report FFD concerns.
6. Describes the individual's responsibility to maintain their FFD and make self-declaration
if they are not fit for duty.
5.2 PROCEDURES
The licensee shall develop, implement, and maintain procedures that:
1. Describe the process to be followed when any individual covered by the FFD program
makes a self-declaration that he or she is not fit to safely and competently perform his or
her duties for any part of a working tour as a result of fatigue.
2. Describe the individuals and licensee's rights and responsibilities related to self-
declaration.
3. Describe requirements for establishing controls and conditions under which an individual
may be permitted or required to perform work after that individual declares that he or she
is not fit due to fatigue.
4. Describe the process to be followed if the individual disagrees with the results of a
fatigue assessment that is required.
5. Describe the process for implementing the work hour controls required for covered
. individuals.
6. Describe the process tobe followed in conducting fatigue assessments.
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.7. Describe the disciplinary actions that the licensee may impose on an individual following
a fatigue assessment, and the conditions and considerations for taking those disciplinary
actions.
The procedure(s) shall include the following responsibilities: [Bracketed text is filled in on a site
specific basis]:
1. The [Operations Shift Manager] or a site senior level manager with requisite signature
authority is responsible for:
* Determining that a work hour waiver is necessary to mitigate or prevent a

condition adverse to safety.
" As applicable, evaluating staffing levels to ensure individual work hours are
managed with the objective of preventing impairment, from fatigue due to the
duration, frequency, or sequencing of successive shifts.
2. The [Security Shift.Managerl or a site senior level manager with requisite signature
authority is responsible for:
* Determining that a waiver is necessary to maintain site security.
" As applicable, evaluating staffing levels to ensure individual work hours are
managed with the objective of preventing impairment from fatigue due to the
3. The IGeneral Manager, Plant Operationsi is responsible for:

* Ensuring a review is performed at least once per year, such that the entire year is
reviewed, to evaluate the effectiveness of the control of work hours, to include:
Evaluating staffing levels to ensure individual work hours are managed with
the objective of preventing impairment from fatigue due to the duration,
frequency, or sequencing of successive shifts.
* Evaluating the performance of individuals to ensure individual work
schedules prevent impairment from fatigue. This includes evaluating the
duration, frequency and sequencing of the hours that are worked by each
individual relative to worker performance.
* Reviewing the performance of the station in adhering to work schedules for
covered work groups: evaluate the number of schedule changes and reasons
for the changes and assess whether or not the schedule is effectively being
implemented.
0 Ensuring that issues identified in the annual review are address in the,
corrective action program.
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4. The ISupervisor or Manager] of the individual who will be issued a waiver to exceed the
work hour limits or who is being assessed for fatigue is responsible for:
* Evaluating the employee's fitness by performing a face-to-face fatigue.
assessment.
* Evaluating the employee's performance and continued fitness-for-duty while
working under a waiver.
* If evaluating for the issuance of a waiver and the individual's Supervisor or
Manager is not on-site, this responsibility may be performed by any manager or
supervisor who is qualified to oversee the work to be performed by the individual.
5. Each lDepartment Headi is responsible for:

* Providing guidelines for overtime selection process, including those required by
the union contract, and the fitness-for-duty requirements outlined in this guide and
in the licensee's FFD Program.
* Communicating the requirements to appropriate personnel within his/her
department.
* Maintaining a record of the shift schedules and shift cycles used for at least the
past 3 years for those individuals who are subject to work hour controls. Records
may be required longer than 3 years, if legal proceedings are ongoing.
* Evaluating staffing levels are adequate to ensure individual work hours are
managed with the objective of preventing impairment from fatigue due to the
6. Each Requesting Supervisor is responsible for ensuring a waiver to exceed working hour
limits is authorized prior to allowing an individual to exceed these limits.
7. Each Employee (licensee or contractor) is responsible for (this is inclusive of the above
listed positions):
" Evaluating his/her personal fitness to work based on impairment from fatigue.
* Managing his/her work hours consistent with the objective of preventing
impairment from fatigue.
* Making a self-declaration of fatigue and discussing his/her concerns with
supervision or management in cases when he/she feels his/her performance may
be impaired.
" Verifying his/her working hours are correctly documented regardless of whether
he/she is paid for the hours worked.
* Monitoring and reporting concerns related to individuals' fitness to work based on
impairment from fatigue (i.e., behavioral observation program).
0 Being aware of the total hours worked in the previous 14 days and notifying
management if work hour limits will be exceeded if asked to work additional
hours.
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6 INDIVIDUALS SUBJECT TO FATIGUE MANAGEMENT AND WORK HOUR

CONTROLS
Reference: 10 CFR Part 26.4 "FFD Program Applicability to Categories of Individuals"
6.1 INDIVIDUALS SUBJECT TO FATIGUE MANAGEMENT
Fatigue management requirements, with exception of work hour controls, apply to the following
individuals:
All persons who are granted unescorted access to nuclear power reactor protected areas,
and
All persons who are required to physically report to the Technical Support Center or
Emergency Operations Facility, in accordance with the site Emergency Plan and
procedures.
6.2 WORK HOUR CONTROLS FOR COVERED INDIVIDUALS
Work hour controls apply to only covered individuals who are granted unescorted access to
nuclear power reactor protected areas. Any individual on-site who performs duties within any of
the following job categories is a covered individual subject to work hour controls:
* Operating or on-site directing of the operation of systems and components that a risk-
informed evaluation process has shown to be significant to public health and safety.
* Performing maintenance or on-site directing of the maintenance of structures, systems,
significant to public health and safety.
emergency response organization minimum shift complement.
" Performing the duties of a Fire Brigade member who is responsible for understanding the
effects of fire and fire suppressants on safe shutdown capability. The person specifically
designated for understanding the effects of fire and fire suppressants on safe shutdown
capability is considered the person responsible for understanding the effects of fire and
fire suppressants on safe shutdown capability. The remaining Fire Brigade members are
not considered as the person(s) responsible for understanding the effects of fire and fire
suppressants on safe shutdown capability.
• Performing security duties as an armed security force officer, alarm station operator,
response team leader, or watchperson, hereinafter referred to as security personnel
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Work hour controls do not apply to the following individuals and activities:
* Maintenance activities on systems, structure and components that are off-site.

* Quality control and quality assurance activities.
* Maintenance as defined per Part 26 does not include activities that have not historically
been defined as maintenance, that are non-intrusive, or pose low risk to the health and
safety of the public such as, calculations, non-destructive analysis (NDE), thermography,
vibration analysis, data collection and analysis.
* Note: At times an activity requires starting or stopping a piece of equipment. The

worker starting or stopping the equipment would be performing covered work under the
operating category; however, the data collection activity would not be considered a
covered work activity.
Contractor/vendors, who are not granted unescorted access (i.e., the individual is
escorted), conducting work on a risk-significant system, structure, or component on-site
Emergency Response Personnel who are not part of the on-site minimum shift
complement.
The licensee program shall clearly define when an individual is subject to work hour controls.
The Maintenance Rule, Requirements for monitoring the effectiveness of maintenance at nuclear
power plants, § 50.65 (a) (4), can be considered a risk-informed evaluation process to identify
SSC's that are significant to public health and safety. The licensee has the option of using risk-
informed evaluation processes other than those used for compliance with the Maintenance Rule.
Example 1:
If an unbadged contractor is brought on-site to do emergent critical specialty work on a risk-

significant component, (such as a contractor who is sealing a risk-significant valve), is that
contractor subject to the work hour limitations? Note that the contractor would be escorted.
Answer: Personnel under escort (i.e., unbadged individuals) are not subject to work hour
limitations.
Example 2:
A risk significant component is removed from on-site to be refurbished or repaired. Is the

work off-site on this component considered covered work?
Answer: No, work on a component that is off-site is not covered work. The work for
removal, installation and testing the component is covered work.
6.3 DIRECTING
For the purposes of compliance with the, rule, directing only applies to operations and
maintenance activities. Directing means the exercise of control over a work -activity by an
individual who is directly involved in the execution of the work activity, and either makes
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October 2008
technical decisions for that activity without subsequent technical review, or is ultimately
responsible for the correct performance of that work activity.
The licensee program shall clearly define when an individual is directing and subject to work
hour controls. Considerations should include all of the following when determining if an
individual is directing an operation or maintenance activity:
" Is the individual on-site?

" Is the individual the first line supervisor/foreman/leader?
" Is the individual directly involved in the execution of the work activity?
" Is the individual making technical decisions for that activity without subsequent technical
review?
" Is the individual ultimately responsible for the correct performance of that work activity?
(For the purpose of this guide, ultimately refers to first level of leadership accountability
for the performance of.the task.)
(See the following flow chart.)
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Is the work activity an operations or

maintenance activity?
No
Y
Yes
Is the work activity on a risks gnificant NO- I

structure, system orcomponent?: i
Yes
-No-
IIs the-individual in question onsite? •
Yes
V
I's the individual the first line supervisor N
foremanlleader? N
'Is the individual direictlyinvolved

in the execution of the work -No-
activity?
Yes
Y 2IS the individual making technical

No---- Is this person ultimately
ducisions for that activirv without responsible for the correct 2
9 N.-T
subse(jQunt technical review tperformance of the work
Hi
-- Yes-
Directin~g', -No--
Not directing !
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October 2008
The following tasks are examples generally considered NOT directing:
" Engineering tasks

" Supervision in the plant of the maintenance on a non-covered SSC
* Supervision at the second level supervision
* NOTE: Position alone should not be the deciding factor. For example a Shift Manager is
a second level supervisor but, in practice and as defined in 1OCFR, has the authority to
direct covered activities. Careful analysis, evaluating all the criteria, should occur prior
to determining applicability or exclusion.
* Conducting Work Control Center documentation activities
* Writing a work procedure
* Preparing awork or modification package
* Review by senior management of work plans
* Training of personnel during which time the trainee is not operating or performing
maintenance activities
* Providing recommendations from vendors and engineers on test performance, component
and system operation, or other similar technical inputs
* Review and approval of documents
* Any work that is not operations or maintenance on risk significant SSCs
" Technical Staff providing only recommendation to control room staff
Example 1:
On Sunday morning at 0400, while running the # 1 DG, a problem develops that requires the
System Engineer to return to site to provide technical assistance. The maintenance crew
performing work on the #1 DG is being supervised by a first line maintenance supervisor. The
system engineer provides technical information and makes recommendations to the maintenance
supervisor. Is the System Engineer a covered individual?
Answer: The System Engineer is providing information to the supervisor of a maintenance

crew. The maintenance supervisor in this case would be responsible for deciding what
information is to be acted on and for directing the maintenance activities associated with the
job. The system engineer is not directing and therefore not performing covered work.
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NET 06-11 (Revision 1)
October 2008
Example 2:
A diesel generator (DG) system engineer is supporting a diesel generator system window by
providing technical decisions in the field directly to workers who are acting on the input without
subsequent review or challenge by the job supervisor. Is the system engineer directing?
Answer: Yes, the system engineer is directing as defined by the rule as the covered workers
are taking and acting on the input provided by the engineer without subsequent review,
challenge, or decision-making processing by a supervisor.
Example 3:
The Reactor Engineer is required by station procedures to be present during fuel movement. The
Reactor Engineer's function is to observe the fuel movement activity and provide technical
recommendations to the fuel handling SRO. Is the Reactor Engineer a covered individual?
Answer: The Reactor Engineer is not directing, they are providing technical information and
observing and therefore not conducting covered work. The fuel handling SRO would be
directing and is a covered individual.
Example 4:
The Reactor Engineer is required by station procedures to be present during reactor startup. The
Reactor Engineer's function is to provide information to the control room supervisor on the
reactivity of the reactor during the approach to criticality. Is the Reactor Engineer a covered
individual?
Answer: The Reactor Engineer is not directing, they are providing technical information and
therefore not conducting covered work. The control room supervisor would be directing and
is a covered individual.
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October 2008
7 WORK HOURS SCHEDULING
Work Hour Scheduling

Reference: 10 CFR Part 26.205(c)
This section covers the normal long range schedule used for covered individuals. Licensees shall
schedule the work hours of covered individuals consistent with the objective of preventing
impairment from fatigue due to the duration, frequency, or sequencing of successive shifts.
Licensees should have a procedure on establishing schedules.
The licensee may elect to use a rolling (maximum) 6 week period for the purposes of
determining the minimum days off. The actual repeatability of the rotation may exceed 6 week;
however, the shift cycle used for calculating the minimum days off cannot exceed 6 weeks.
When establishing schedules the following should be applied consistent with the performance
objective of preventing impairment from fatigue due to the duration, frequency, or sequencing of
successive shifts:
" Duration of scheduled work period (not to exceed 12 hours)

* Duration of break period
" Consistent start times for work periods (e.g. 6 or 7 a.m.)
" Considerations of start times consistent with circadian factors.
" Consistent stop times for work periods
* Consistent rotation (e.g., if working a 5-week shift rotation, the scheduled work days and
days off are repeated every five weeks)
* Stable 24-hour shift rotation (e.g., 3 X 8's, 2 X 12's, 2 X 10's with four hours un-staffed)
* The impact of backward shift rotation (rotation of the start of the shift from days to night
to swings).
* Rotating schedules provide suitable transition between shifts (days/nights,
days/swings/nights), 8-hour shift rotations rotate forward or provide more than 24 hours
between work periods to adjust circadian rhythm; 12-hour shift rotations provide 34
hours off during day/night transitions.
* Long range predictability is a key aspect of fatigue mitigation.
* Circadian factors- fixed vs. rotating shifts
* Training requirements
* Vacation scheduling
* Consideration of the impact of unscheduled overtime
Staffing levels should be sufficient so that schedules (over non-outage periods) for the covered
individuals can be maintained based on vacation and emergent training demand without relying
on waivers. It is expected and allowed that normal variation in the vacation demand and training
demand may occasionally require additional work hours to be used. Management is responsible
for understanding the total vacation, training, and work loads, and for maintaining sufficient staff
to get the work done. Normal variation in the vacation demand, training demand, and emergent
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October 2008
or extraordinary work demands will require periodic overtime. Section 15, Reviews, addresses
an annual performance based assessment of the work schedule.
7.1 PERIODIC OVERTIME
Periodically, workers and supervisors will need to work overtime to meet station needs. This
overtime will be worked while meeting all work hour rules, for both time at work, break
requirements, and minimum days off, consistent with the individual's shift schedule.. The use of
Periodic Overtime shall be evaluated by plant management on a quarterly basis as described
below.
To distinguish between periodic overtime and an actual change of shift, the following need be
considered:
* Is the time worked on the different shift duration for a period of time less than the shift
cycle duration?
* Is the change in shift duration not at a regular frequency or multiple times throughout the
year?
* Is the change in shift duration for a specific reason (specific work window support,
special test, pre- or post-outage period, etc.) with a defined purpose and duration?
The relationship between established schedules and periodic overtime can be summarized as
follows:
* The licensee prepares a shift schedule that meets the requirements of § 26.205(c) -
" Minimum Days Off Requirements of § 26.205(d)(3) are applied for that assigned shift
schedule
* Overtime assigned is maintained within the guidance of the work hour rules per §
26.205(d)(1) and breaks applied per § 26.205(d)(2)
* The Corrective Action Program is used to identify and evaluate the conditions which lead
to individuals working an average of more than 54 hours per week within a shift cycle
The.use of Periodic Overtime shall be evaluated by plant management on a quarterly basis as

follows: The average work hours of covered employees will be reviewed on at least a quarterly
period and instances of covered workers exceeding an average of 54 hours in a shift cycle will be
documented in the corrective action program and reviewed to determine if a shift change is
appropriate.
7.2 TRANSITIONS BETWEEN SCHEDULES
Individuals may change shift schedules during the shift cycle. The following guidance applies:
For shift schedule transitions, licensees should calculate the average duration of the shifts
worked and to be worked during a period of not more than six weeks that encompasses the
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October 2008
schedule transition to determine the applicable day off requirement. If the average shift duration
is not more than 9 hours, then the minimum day off requirements for 8-hour shift schedules
would apply. If the average shift duration is more than 9 hours but not more than 11 hours then
the requirements for a 10-hour shift would apply. If the average shift duration is more than 11
hours then the requirements for a 12-hour shift apply.
7.3 TRANSITIONING ONTO A SHIFT OR BETWEEN COVERED GROUPS OR INTO A COVERED

GROUP
If an individual begins or resumes performing for the licensee any covered work during the
calculation period, the licensee shall include in the calculation of the individual's work hours all
work hours worked for the licensee, including hours worked performing duties that are not
covered work and control the individual's work hours in accordance with the following
requirements:
Except as permitted by waivers and exceptions, licensees shall ensure that any individual's
work hours do not exceed the following limits:
* 16 work hours in any 24-hour period

* 26 work hours in any 48-hour period
* 72 work hours in any 7-day period
Except as permitted by waivers and exceptions, licensees shall ensure that individuals
have the following breaks and minimum days off:
" A 10-hour break between successive work periods, or an 8-hour break between
successive work periods when a break of less than 10 hours is necessary to
accommodate a crew's scheduled transition between work schedules or shifts.
* A 34-hour break in any 9-calendar day period
* A minimum of 1 day off in the preceding 7-day period is acceptable for
individuals to begin or resume covered duties and for individuals who have been
working an 8-hour shift schedule, as either day or shift workers, and are
transitioning (1) from a non-covered group to a covered group or (2) from a
covered group to another covered group that has more stringent MDO
requirements
* A minimum of 2 days off in the preceding 7-day period is acceptable for
individuals who have been working a 10- or 12-hour shift schedule, as either day
or shift workers, and transition (1) from a non-covered group to a covered group
or (2) from a covered group to another covered group with more stringent MDO
requirements
* A minimum of 2 days off in the preceding 7-day period is acceptable for operators
who have been working outage hours on 10- or 12-hour shifts before they
transition to the non-outage unit as one of the two required operators working
non-outage minimum days off. This does not preclude short term relief of the
non-outage unit operators as described in Section 8.3.
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October 2008
Example 1:
Assume that John Doe is a staff engineer in the Operations department who holds an active
license. John works a nominal 8-hour day. John's normal work duties are NOT within the
scope of the work hours rule. Over the last 6 weeks John has had weekends off except for the
6th week; i.e., during the 6th week (i.e., last week) John worked Monday through Friday,
came in on Saturday for 4 hours to catch up on work; and also came in Sunday for 4 hours.
John resumed his normal duties on Monday this week. Today, (Tuesday), John is asked to
stand an 8 hour shift schedule SRO watch. Can he stand the watch since Tuesday is the 9th
day in a row that John will be working?
Answer: No, John has not had a 34-hour break in the last 9-calendar day period nor has
John had a day Off in the last 7 days.
Example 2:
Assume that Jane Doe is a staff engineer in the Operations department who holds an active
license. Jane works a nominal 8-hour day. Jane's normal work duties are NOT within the
scope of the work hours rule. Over the last 6 weeks Jane has had weekends off except that
Jane as a normal routine works 4 hours every Saturday morning. Jane resumed her normal
duties on Monday this week. Today, (Tuesday), Jane is asked to stand a 12 hour shift
scheduleSRO watch. Can she stand the watch?
Answer: Yes, Jane has had a 34 hour break in the last 9 days. Jane works an 8-hour
shift and a look back over the last 7 days shows that she does meet the minimum 1 day
off requirement.
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October 2008
7.4 UNEXPECTED OUTAGES
Unexpected outages can impact the licensee's ability to demonstrate compliance with the normal
operations day off requirements. Average minimum days off are applicable during non-outage
periods. During an outage, days off are required on a day (e.g., 1 day off per week for
maintenance workers and 3 or 4 days off every non-rolling 15 day period for the remainder of
the covered individuals) basis and not on an average basis. When entering an unexpected outage,
the licensee shall be considered to be in compliance with the rule if the schedule for the shift
cycle would have provided for the required minimum days off.
Example: Plant Online Week 1 (Days 1-7), Forced Outage Weeks 2-5 (Days 8-35). After
Week 1, Crews adopt outage schedule, adhering to outage work hour restrictions.
Work schedule
Plant status = Normal Operations
Typcal Schedule - Operations Crews
D = 12 hour day shift from 07:00 am to 07:00 pm
N = 12 hour night shift from 07:00 pm to 07:00 am
T = 10 hour training shift from 07:30 am to 5:30 prn
Total cycle is for a 5 crew, 35 day rotation.
Crew/Day 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35
M f W T IFSISIMIT W T FI S SIM T W IT IFI S S M "f WIT F1 S S M T W T F S S
A D 0D D D0 - F TI __ D IN
BN D: r4 _D
CN *T>I D DtDD
E iiD D D D ~ T; TT
Legend
Day Shift N Night Shift [ ] Training
Days Off Per Week Averaged Over Shift Cycle during Periods of Normal Operations (i.e.,
during Week 1)
Crew A: 6
Crew B: 3
Crew C: 1
Crew D: 3
CrewE: 4
The above schedule show that the licensee was currently in compliance and would have been in
compliance with the minimum days off over the remainder of the shift cycle and thus is
considered in compliance with the rule when transitioning to the outage work hours. The licensee
shall meet the outage work hour requirements during the outage.
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October 2008
7.5 RESET FROM DEVIATIONS
Deviations from the requirements from the rule may occur as the result of administrative errors
or unforeseen circumstances and may constitute violations of rule requirements. A person is
considered "reset" from a deviation, whether under a waiver or otherwise, .when they are less
than the minimum hour requirements l6/24, 26/48, 72/7, have had at least 10 hours off since last
at work, and actions are in place to ensure they will meet the minimum days off requirement for
their current shift cycle or outage window (7 days or 15 days). The corrective action program
shall be utilized to document deviations from the rule requirements
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October 2008
8 MANAGING HOURS WORKED
Reference: 10 CFR Part 26.205(b)
This section addresses what the expectations are relative to the work hour limits and what
records are needed to document compliance. Management and covered individuals should be
equally responsible for properly managing work hours.
8.1 CALCULATING HOURS WORKED
The concepts for this section are:
* Work hour limits and the associated calculation and tracking of work hours apply to the
individuals who perform covered work.
* Licensees shall establish the accounting practices to be used in monitoring hours worked.
In many cases this will parallel the established system for compensation. However the
accounting practices may be different from record keeping for payroll purposes. Work
periods should be rounded consistently.
* Work hour records should show the number of hours worked each calendar day. Work
period start and stop times should be recorded and documented in a consistent manner.
The licensee shall calculate the work hours of covered individuals subject to this section as the
amount of time the individuals perform duties for the licensee. The calculated work hours shall
include all time performing duties for the licensee, including all within-shift break times and rest
periods during which there are no reasonable opportunities or accommodations appropriate for
restorative sleep.
Work hours are calculated as the amount of time an individual performs any duties for the
licensee including but not limited to the following:
• All within-shift break times and rest periods during which there is no reasonable
opportunity or accommodations appropriate for restorative sleep (e.g., a nap);
* Shift holdovers to cover for late arrivals of incoming shift members;
* Early arrivals of individuals for licensee required meetings, training, or pre-shift briefings
for special evolutions (these activities are not considered shift turnover activities); and
* Holdovers for interviews needed for event investigations.
For the purposes of calculating the average number of days off, the duration of the shift cycle
shall not exceed 6 weeks and may be of a shorter duration.
To ensure an individual's work hour limits are not exceeded, the following guidance should be
used:
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October 2008
(a) The periods of "24-hours," "48-hours," and "7-days" are considered rolling time
periods. Rolling means -the period is not re-zeroed, or the "clock reset" following a
day off or after obtaining authorization to exceed the limits. The "24-hours," "48-
hours," and "7-days" periods do not restart after a day off, the periods continue to
roll.
(b) Hours worked should be evaluated to determine if any limit will be exceeded based
on the work schedule by picking a future time (T) on the work schedule and asking,
"how many hours will have been worked during the T-24 hours, T-48 hours, or T-168
hours (T-7days)" (i.e., a backwards look at the number of hours that have or will have
been worked based on a time in the future.)
(c) If a work hour limit will be exceeded, it shallbe identified before the hours are
worked. To determine if the minimum days off requirements will be met (before
working the additional hours) a licensee may use one of the following methods:
Calculate the minimum days off based on a backwards look of the previous 5 weeks
and determine if the extra hours worked in the next week would still meet the
requirement (rolling 6 week cycle method); or ensure that sufficient days off still
exist (within the shift cycle) to meet the minimum days off requirements (fixed shift
cycle method).
(d) The period is not re-zeroed, or the "clock reset" following a day off or after obtaining
authorization to exceed the limits.
For example, if an individual who normally works a 12-hour shift schedule is requested to work
additional hours from 0700 to 1900 on Friday, the following should be considered prior to
working the additional hours.
o- To determine if more than 16 hours in any 24-hour period will be exceeded, review all
hours worked during the 24-hour period prior to the stop time on Friday as reflected in
the request to work additional hours..
* To determine if more than 26 hours in any 48-hour period will be exceeded, review all
hours worked during the 48-hour period prior to the stop time on Friday as reflected in
the request to work additional hours..
* To determine if more than 72 hours in any 7-day period will be exceeded, review all
hours worked during the 7-day period prior to the stop time on Friday (i.e., T-168 hours)
as reflected in the request to work additional hours.
* To determine if a 10-hour break has been taken, review the break period(s) between the
last day of work before Friday and 0700 on Friday..
* To determine if a break of at least 34 consecutive hours has been taken, review the break
period(s) during the last 9 days prior to the stop time on Friday..
* To determine if the minimum days off requirement for the current shift cycle is impacted.
Within-Shift Breaks and Rest Periods
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October 2008
(a) Only that portion of a break or rest period during which there is a reasonable
opportunity and accommodation for restorative sleep (e.g., a nap of at least 30
minutes) may be excluded.
(b) Time spent at lunch, although non-productive work may not be excluded from the
work hour calculations.
(c) Any other break time allowed during the scheduled work day that does not allow
opportunity or accommodations for restorative sleep (e.g., a nap) is included in the
work hour calculation.
Paid Time Not Included in the Work Hour Calculations
(a) Pay for hours not worked - Only the actual hours worked are included in the work
hour calculations. Examples of paid hours not worked follow:
0 Vacation time - this is time away from work and is not included in the work hour
calculation.
* Sick leave - this is time away from work and is not included in the work hour
calculation.
0 Personal leave - this is time away from work and is not included in the work hour
calculation.
0 Holiday pay - this may be either time away from work or at work. If the time is at
work, then only the actual hours worked are included in the work hour
calculation.
(b) Declared Plant Emergencies as defined in the licensee's emergency plan.
(c) Unannounced emergency preparedness exercises and drills. Licensees may exclude
from the calculation of an individual's work hours the time the individual works
unscheduled work hours, above the normal scheduled work hours, for the purpose of
participating in the actual conduct of an unannounced emergency preparedness
exercise or drill. If an individual is on a day off, it is still considered a day off.
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Call-in work period
A call-in is considered an addition to the normal work schedule. The work hours can be
accounted for using three different methods depending on timing and circumstances of the call-in
work period.
(a) The call-in hours can be considered a separate work period. Using this method, only
the hours worked for the licensee will be counted. The method requires a 10 hour
break before the call in period and after the call-in period.
(b) The call-in hours can be considered an extension to the preceding or succeeding work
period. Using this method, the intervening hours of the extended work period must
be counted.
(c) A waiver can be processed for the required 10 hour break between successive work
periods. The requirements of Section 9, Waivers, apply to this method.
Example 1:
An individual's normal schedule is from 0700 to 1530 (8 hour day) and the individual is called
back to work at 1900 and he/she works until 2100.
a) The separate work period method cannot be used as a 10 hour break is not available
prior to the call-in period.
b) The call-in is considered an extension of the previous work period, 0700 to 1530.
The hours counted for this work period would be 14. A ten hour break is required
prior to the individual starting an additional work period; therefore, the individual
could return at the normal start of their work period at 0700 the next day.
c) A waiver to the 10 hour break between successive work periods could be performed.
The hours counted for the work day would be 10.5. The individual could return at
the normal start of their work period at 0700 the next day.
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October 2008
Example 2:
An individual's normal schedule is from 0700 to 1530 (8 hour day), and the individual is called
back to work from 0200 to 0400 the next day.
(a) The call in period is considered a separate work period. The 2 hours worked for the
licensee is counted. The individual had a 10 hour break prior to the start of the work
period and must be given a 10 hour break following the end of the work period.
(b) The call-in is considered an extension of the succeeding work period, 0700 to 1530.
The hours counted for this work period would be 13.5.
(c) A waiver should not be necessary in this example.
Daylight Saving Time
When working during the change from standard time to daylight savings time, the shift being
worked during the time change may be counted as a 7-hour, 9-hour, or 11 hour shift.
When working during the change from daylight savings time back to standard time, the shift
being worked during the time change may be counted as an 8-hour, 10-hour, or 12 hour shift
(i.e., the additional hour does not have to be included in the work hour calculations).
Non-Outage and Outage Days
(a) A non-outage day for a shift is a day when the unit is not in an outage when the shift
starts.
(b) An outage day for a shift is a day when the unit is in an outage when the shift starts.
For example if Crew "A" works from 0700 to 1900 on Friday and the outage starts at 1800 on
Friday, Crew "A" is working a non-outage day. When Crew "B" comes in at 1900 on Friday,
Crew "B" is working an outage day.
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October 2008
The licensee may exclude in the calculation of work hours the following as discussed below:
* Shift Turnover
• Within-shift break and rest periods during which there is a reasonable opportunity and
accommodations for restorative sleep (e.g. a nap)
" Unannounced emergency preparedness exercises and drills
* Incidental duties performed off-site.
Shift turnover
Licensees may exclude shift turnover from the calculation of an individual's work hours. Shift
turnover includes only those activities that are necessary to safely transfer information and
responsibilities between two or more individuals between shifts. Shift turnover activities may
include, but are not limited to, discussions of the status of plant equipment, and the status of
ongoing activities, such as extended tests of safety systems and components. Turnovers for
supervisors may be more extensive than for workers and will therefore may be longer. Turnover
may include time necessary to prepare for specific job requirements for example arming and
disarming times for security guards or donning or un-donning of protective clothing for radiation
workers as necessary to support turn-over.
Licensees may exclude either the oncoming or off going shift turnover, but not both, from the
calculation of break times between successive work periods.
Licensees may not exclude work hours worked during turnovers between individuals within a
shift period due to rotations or relief within a shift. Activities that licensees may not exclude
from work hours calculations also include, but are not limited to, shift holdovers to cover for late
arrivals of incoming shift members; early arrivals of individuals for meetings, training, or pre-
shift briefings for special evolutions; and holdovers for interviews needed for event
investigations.
Within-shift break and restperiods
Licensees may exclude from the calculation of an individual's work hours only that portion of a
break or rest period during which there is a reasonable opportunity and accommodations for
restorative sleep (e.g., a nap).
Unannouncedemergency preparednessexercises and drills
Licensees may exclude from the calculation of an individual's work hours, including days off,
the time the' individual works unscheduled work hours for the purpose of participating in the
actual conduct of an unannounced emergency preparedness exercise or drill.
Incidental duties performedoff-site
Licensees may exclude from the calculation of an individual's work hours unscheduled work
performed off-site (e.g., technical assistance provided by telephone from an individual's home)
provided the total duration of the work, which is required by the licensee, does not exceed a
nominal 30 minutes during any single break period. For the purposes of compliance with the
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October 2008
minimum break requirements and the minimum day off requirements, such duties do not
constitute work periods or work shifts.
After hours study time during training weekls shall be excluded from work hour calculations. As
with any academic setting and curriculum, after hours study time varies from individual to
individual. Appropriate after hours study time compliments the utility provided training to ensure
the learning process occurs and optimal information retention is achieved.
When considering work hour extensions for individuals performing covered work, all hours
worked by the individual shall be included. For example, if an individual has performed 15 hours
of non-covered work, and the individual is needed to perform additional covered work that
extends beyond 16 hours in a 24 hour period, then a waiver to exceed the work hour limits shall
be approved prior to the individual exceeding the 16 hour limit.
On the other hand, if the individual has performed 14 hours of covered work, and is needed to
perform additional non-covered work, then the programmatic approvals of this document do not
apply. However, the additional work hours are included in consideration of any other limits if the
individual subsequently performs covered work.
Example 1:
An individual performs risk-significant work for 10 hours (0700 - 1700) and goes home. At
2200 he/she receives a call from work and talks for 1 hour until 2300 pm. Can he/she return to
work at 0700 the next day?
Answer: The individual did not have a 10 hour break prior to receiving the call. The hours
from 1700 through 2200 do not count with respect to calculating hours worked. The
individual worked a total of 11 hours with the work period ending at 2300. However, the
individual cannot return to work at 0700 the next day; he/she would not meet the 10-hour
break requirement. The individual could begin work at 0900 the next day.
Example 2:
If an individual is on a day off and is required to talk with licensee personnel at the plant on 3
occasions, with each call lasting 20 minutes, totaling 1 hour, can that day still be considered a
day off since that one hour shall be included in the work hour total.
Answer: The total time spent on the phone shall be counted since it exceeds a nominal 30
minutes during a single break period; therefore, the total time spent on the telephone call
must be documented as an hour worked. The day is considered a work day.
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Example 3:
What "work-related" activities may be done at home on a day off without violating the "day off'
intent? For example, may an individual read procedures, catch up on administrative tasks, or
study for a license requalification exam for a number of hours and still count that day as a "day
off'?
Answer: Activities initiated by the individual (not required by the licensee) may be
performed at home on a day off and not be considered "work," e.g., studying, reading work-
related material, reading email. These activities would not violate the 30 minute incidental
duties requirement and would, therefore, not be counted toward the work hour total.
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October 2008
8.2 WORK HOUR CONTROLS DURING NON-OUTAGE PERIODS
During non-outage periods, licensees shall control the work hours of covered individuals as
follows:
1. Except as permitted by waivers and exceptions, licensees shall ensure that any
individual's work hours do not exceed the following limits:
a. 16 work hours in any 24-hour period
b. 26 work hours in any 48-hour period
c. 72 work hours in any 7-day period
2. Licensees shall ensure that individuals have, at a minimum, the rest breaks specified
below. A break is defined as an interval of time that falls between successive work
periods, during which the individual, does not perform any duties for the licensee other
than one period of shift turnover at either the beginning or end of a shift but not both.
have, at a minimum:
a. A 10-hour break between successive work periods, or an 8-hour break between

b. A 34-hour break in any 9-calendar day period.
3. Licensees shall ensure that individuals have, at a minimum, the number of days off
specified below. For the purposes of breaks, a day off is defined as a calendar, day in
which an individual does not start a work shift. For the purposes of calculating the
average number of days off, the duration of the shift cycle may not exceed 6 weeks.
Covered 8- hour shift 10- hour shift 12- hour shift

Individual Days off* Days off* Days off*
Maintenance 1 day off per 2 days off per 2 days off per
week week week
Operations, HP, 1 day off per 2 days off per 2.5 days off per
Chemistry, Fire week week week
Brigade
Security 1 day off per 2 days off per 3 days off per
week week week
*Averaged over a shift cycle
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October 2008
8.3 WORK HOUR CONTROLS DURING OUTAGES, SECURITY SYSTEM OUTAGES, OR

INCREASED THREAT CONDITIONS
Transitioning Into/Out of an Outage, Security System Outages, or Increased Threat

Conditions
When entering an unplanned outage, unplanned security system outage, or increased threat
condition, the licensee shall be considered to be in compliance with the rule if the schedule for
the shift cycle would have provided for the required minimum days off.
For security personnel during the first 60 days of an unplanned security system outage or
increased threat condition, licensees need not meet the minimum days off requirements of §
26.205(d)(3) nor the requirement for 4 days off in every non-rolling 15 day period in §
205(d)(5)(i).
The following options for managing the transition into or out of an outage can be used:
" Using shift cycles of less than six weeks in length;

* Changing shift duration;
* Using a rolling 6-week average.
* A new shift cycle can be used at the completion of an outage.
Licensee employees may go from an outage at one site to an outage at another site. When a
licensee employee works for one licensee during two or more unit outages or security system
outages (or a combination thereof), and the interval(s) between successive outages is less than 9
days, licensees should determine that the individual has had a 34 hour break period and that the
individual has not exceed the following limits:
1. 16 work hours in any 24-hour period
2. 26 work hours in any'48-hour period
3. 72 work hours in any 7-day period.
Workers Eligible to Work Outage Hours
10 CFR 26 Subpart I defines outages as the reactor unit is disconnected from the electrical grid.
Also, 10 CFR 26 Subpart I uses the term "working on outage activities." However, 10 CFR 26
Subpart I does not define the term "working on outage activities." Thus, this section provides a
description for outage activities.
10 CFR 26 Subpart I has different days off requirements during outage periods than during
normal (online) operations. The differing requirements acknowledge the unique and temporary
nature of outage activities while requiring hour limitations and work day breaks. While there are
many considerations that need to be evaluated when determining who the outage work hour
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October 2008
restrictions apply, the determination must takes into consideration the safety of the operating unit
and the unit in the outage.
Outage activities are activities associated with the outage unit and common systems including
covered and non-covered tasks performed while the unit is disconnected from the electrical grid.
Examples of unit outage activities include but are not limited to the following;
* activities included in the outage schedule.

* planning and scheduling activities
* emergent work that impacts the outage unit
* review and impact of activities included in the outage schedule
* switchyard activities,
* corrective maintenance,
* elective maintenance
* preventive maintenance
* calibrations,
" safety tagging,
* staging of equipment and tools,
* valve lineups and verifications,
* system readiness inspections,
" post maintenance testing,
" surveillance testing,
* system walkdowns,
" containment mobilization and demobilization
" refueling
" fuel movement in the spent fuel pool
* Housekeeping walkdowns and inspections
* FME activities
* Management observations
* Operation, monitoring and alarm response of outage systems and common systems
* Operation, monitoring and alarm response of stand alone systems required to support the
outage unit such as auxiliary boiler
* Construction activities
* Scaffold installation and removal
" Temporary power installation and removal
• Decontamination activities
* Radiation protection activities
" Processing of waste water
* Outage work control and communication
* Participation in pre and post job briefs for outage tasks and common systems
* Outage unit project coordination
• Testing of component on the outage unit or common systems
* Pre and'post shift turnover briefing of outage unit and common systems
* Sampling of outage unit and common systems
34
October 2008
* Chemical addition to outage unit and common systems

" Post event investigation for outage unit and common systems
4 Receipt of materials in support of the outage
* Just in time training of outage activities
Workers that are eligible to work outage hours shall meet the following criteria:
" covered workers at single sites working on outage activities are eligible
" covered workers at multi unit sites with one unit in an outage that are working on outage
activities are eligible
* covered workers, due to Emergency Response Organization, Fire Brigade, or Security
duties, at a multi unit sites with a unit in an outage are eligible
* covered workers at multi unit sites that work on both outage activities and operating unit
activities are eligible, with the exception described below
Workers Not Eligible to Work Outage Hours
* 1 Reactor Operator assigned to the controls and 1 Senior Reactor Operator assigned to the
controls for each operating unit at a multi-unit station while any unit is in an outage. This
does not prevent short term relief of these two licensed operators by licensed operators
that are eligible for outage work hours
Eligibility should be established on an individual or defined group basis. Eligibility should be

evaluated each 15 days for each individual or defined group during the outage.
Return to normal work hour limitations starts a new shift cycle. The licensee shall be considered
to be in compliance with the rule if the schedule for the shift cycle would have provided for the
required minimum days off.
Following are examples of Covered Workers that may be affected by outage work hour
limitations:
Example 1 - A maintenance or operations worker at a multi-unit site that has

responsibilities for outage activities. These workers are eligible for outage work hour
limitations.
Example 2 - A Maintenance worker at a multi-unit site that performs tasks exclusive to
the operating unit not including common systems. This maintenance worker is not
eligible for outage work hour limitations.
Example 3 - A Maintenance worker at a multi-unit site with responsibilities for activities
on the operating unit, outage unit and, common systems. This maintenance worker is
35
October 2008
Example 4 - An operator at a multi-unit site with responsibilities for activities on the

operating unit, outage unit, and common systems. This operator is eligible for outage
work hour limitations
Example 5 - A system engineer reassigned as a temporary maintenance supervisor
providing direct oversight and decision making to a maintenance crew. This engineer is
Example 6 - A Chemistry or Radiation Protection worker at a multi-unit site with ERO
responsibilities assigned activities for the site. This chemistry worker is eligible for
outage work hour limitations.
Example 7 - The fire brigade leader assigned activities for the site is eligible for outage
work hour limitations.
Example 8 - Security personnel assigned activities for the site is eligible for outage work
hour limitations.
Example 9 - An operator at a multi-unit site that is performing activities on the outage
unit and is following outage work.hour requirements can be assigned to activities on the
operating unit. The operator that is on outage work hour restrictions cannot be assigned
as the operator at the controls for the operating unit except for short term periods of
relief.
Example 10 - A covered worker that is following the work hour restriction for a
non-outage unit can be assigned to outage activities.
36
October 2008
Control of Work Hour during an Outage, Security System Outages, or Increased Threat
Conditions
During an outage, licensees shall control the work hours of covered individuals who are
considered outage workers as follows:
1. Except as permitted by waivers and exceptions, licensees shall ensure that any
individual's work hours do not exceed the following limits:
a. 16 work hours in any 24-hour period
b. 26 work hours in any 48-hour period
c. 72 work hours in any 7-day period
2. Licensees shall ensure that individuals have, at a minimum, the rest breaks specified
below. A break is defined as an interval of time that falls between successive work
periods, during which the individual does not perform any duties for the licensee other
than one period of shift turnover at either the beginning or end of a shift but not both.
have, at a minimum,
a. A 10-hour break between successive work periods, or an 8-hour break between

b. A 34-hour break in any 9-calendar day period.
3. During the first 60 days of a unit outage licensees shall ensure that individuals have, at a
minimum, the number of days off specified below. For the purposes of breaks, a day off
is defined as a calendar day in which an individual does not start a work shift.

Individual Days off* Days off Days off
Maintenance 1 day off per 1 day off per 1 day off per
week week week
Operations, HP, 3 days off in 3 days off in 3 days off in
Chemistry, Fire each successive each successive each successive
Brigade (i.e., non-rolling) (i.e., non-rolling) (i.e., non-rolling)
15-day period 15-day period 15-day period
Security 4 days off in 4 days off in 4 days off in
each successive each successive each successive
(i.e., non-rolling) (i.e., non-rolling) (i.e., non-rolling)
15-day period 15-day period 15-day period
*The Licensee has the alternative of leaving workers on normal work hour restrictions
during outage periods.
37
October 2008
For an 8-hour shift, the non-outage minimum days off requirements are less restrictive
than the outage minimum days off requirements. The following table shows the
minimum days off requirements allowable during an outage using the operating hours for
the 8-hour shift:

Individual Days off Days off Days off
Maintenance 1 day off per 1 day off per 1 day off per
week week week
Operations, HP, 1 day off per 3 days off in 3 days off in
Chemistry, Fire week each successive each successive
Brigade (i.e., non-rolling) (i.e., non-rolling)
15-day period 15-day period
Security 1 day off per 4 days off in 4 days off in
week each successive each successive
(i.e., non-rolling) (i.e., non-rolling)
15-day period 15-day period
4. The 60-day periods may be extended for each individual in 7-day increments for each
non-overlapping 7-day period in which the individual has worked not more than 48 hours
during the unit or security system outage or increased threat condition, as applicable.
5. Contractor/vendors are responsible for tracking and reporting their hours between
outages.
Example:
If during the 1st 60 days, a covered worker gets a 7 day block where he works not more than 48
hours, you can extend the 60-day period by 7 days. If the worker gets 2 7-day blocks where he
does not work more than 48-hours and the 2 periods do not overlap, can you extend the 60 day
period by 14 days?
Answer: Yes, you can extend the 60 day period by 14 days. This extension can be made
anytime in the outage period after the less than 48 hour work week.
38
October 2008
Example:
An individual has not worked for a licensee on a nuclear unit outage with work hour controls for
14 days. The individual starts work on outage day 15. Can the worker be placed under the outage
work hour controls only for a period of 45 days?
Answer: The 60 day period is defined by the start of the outage. The worker can be placed
under the outage work hour controls only for a period of 45 days. The worker may also be
available for a 14 day extension if the worker did not work more than 48 hours during each
of the prior weeks. A worker that was on vacation during the 14 day period would be eligible
for a 14 day extension. This extension for outage work hour controls cannot be extended into
a non-outage periods.
During the first 60 days of an unplanned security system outage or increased threat condition the
non-outage and the outage minimum days off restriction are not applicable.
39
October 2008
9 WAIVERS
Waivers" are only applicable to covered workers.
The process for granting waivers includes the following distinct steps:
1. Identification by the job supervisor that a waiver is needed:
''Name of the individual for which a waiver is to be requested.

* Date and time the request is initiated.
* Limits for which a waiver is required.
* Date and time waiver would start.
* Duration of the waiver requested. For example, how many hours beyond 16?
* Description of the work to be performed. This should be in adequate detail to support
the supervisory (operations or security shift manager) fatigue assessment.
* Circumstances that caused the job extension.
* Identify that the waiver is required to address conditions that are adverse to security
or safety
2. Review and approval by the operations shift manager or security shift manager.
* Basis for approval

* Name, signature, date, and time
3. Supervisory assessment (Note: Shall be completed before start of waiver period.)
* Work history for past 14 days as reported by the individual for whom the waiver is
requested.
* A statement of how the following were considered:
* Potential for acute fatigue-time since last 10 hour break.
* Potential for cumulative fatigue-review work history above.
* Circadian factors-time of day and recent work cycle.
* Observation and statements of the individual.
* How fatigue could affect the work quality, if at all.
* Nature of work to be performed.
* Are controls -and conditions on work required? If yes describe.
* Name, signature, date, and time review completed.
4. Closeout. In many cases waivers are generated as a contingency for a job and not used.
The information in this section is to support the periodic reviews that are required.
* Hours actually worked, beyond limits, under this waiver.

* Did the individual perform satisfactorily?
40.
NEI 06-I1 (Revision 1)
October 2008
* Name, signature and date of job supervisor or individual for whom waiver was
granted.
Granting Waivers
Licensees may grant a waiver of the work hour controls as follows:
In order to grant a waiver, the licensee shall meet the following requirements:
1. An operations shift manager determines that the waiver is necessary to mitigate or

prevent a condition adverse to safety, or a security shift manager determines that the
waiver is necessary to maintain site security, or a site senior-level manager with
requisite signature authority makes either determination.
2. A supervisor assesses the individual face to face and determines that there is
reasonable assurance-that the individual will be able to safely and competently
perform his or her duties during the, additional work period for which the waiver will
be granted. The supervisor performing the assessment shall be trained in accordance
with the requirements of §§ 26.29 and 26.203(c) and shall be qualified to oversee the
work to be performed by the individual.
3. If there is no supervisor on site who is qualified to oversee the work, the assessment
may be performed by a supervisor who is qualified to provide oversight of the work
to be performed by the individual. The supervisor, if knowledgeable of the work
activity, can be a second level supervisor or a manager in the chain of command.
4. At a minimum, the assessment must address the potential for acute and cumulative
fatigue considering the individual's work history for at least the past 14 days, the
potential for circadian degradations in alertness and performance considering the time
of day for which the waiver will be granted, the potential for fatigue-related
degradations in alertness and performance to affect risk-significant functions, and
whether any controls and conditions must be established under which the individual
will be permitted to perform work.
To the extent practicable, licensees shall rely upon the granting of waivers only to address
circumstances that could not have been reasonably controlled.
Licensees shall ensure that the timing of the required face-to-face supervisory assessment
supports a valid assessment of the potential for worker fatigue during the time the individual will
be performing work under the waiver. Licensees may not perform the face-to-face assessment
more than four hours before the individual begins performing any work under the waiver.
Licensees shall document the bases for individual waivers. The documented basis for a waiver
must include a description of the circumstances that necessitate the waiver, a statement of the
scope of work and time period for which the waiver is approved, and the bases for the required
determinations.
41
October 2008
10 PERSONNEL ACTIONS
Reference: 10 CFR Part 26.203(b)(4)
Procedures describing disciplinary actions related to fatigue shall address the employee's right to
self-declaration that they are not fit for duty as a result of fatigue.
Individuals that exhibit chronic self-declaration that they are not fit for duty as a result of fatigue
should be considered for referral to the employee assistance program.
Individuals that exhibit chronic self-declaration that they are not fit for duty as a result of fatigue,
absent a sound medical reason, may be subject to disciplinary action.
0 Personnel are required to be fit for duty and getting sufficient rest is required to
ensure a person is not subject to fatigue.
* Persons who make choices that result in less than the sleep necessary for that person
to remain alert and avoid fatigue are not meeting their obligation per this rule.
The refusal on the part of an individual to submit to a fatigue assessment shall subject the
individual to disciplinary action and possible removal from unescorted access.
Facts to be considered in assessing disciplinary action shall include the employee's job
assignment, past work record, and work schedule.
Personnel subject to the fatigue assessments who refuse to be assessed will be considered
fatigued and unable to perform their duties. Time away from work for fatigue management
recovery shall be classified as vacation, personal time (if available), or non-paid time.
42
October 2008
11 EXCEPTIONS
The licensee may use the following exceptions to work hour controls:
Force-on-forcetacticalexercises
For the purposes of compliance with the minimum day off requirements, licensees may exclude
shifts worked by security personnel during the actual conduct of force-on-force tactical exercises
evaluated by the NRC when calculating the individual's number of days off.
Common defense andsecurity
Licensees need not meet the work hour requirements when informed in writing by the NRC that
these requirements, or any subset thereof, are waived for security personnel in order to assure the
common defense and security, for the duration of the period defined by the NRC.
Plant emergencies
Licensees need not meet work hour scheduling and work hour controls requirements during
declared emergencies, as defined in the licensee's emergency plan.
43
October 2008
12 FATIGUE ASSESSMENTS
12.1 CONDITIONS FOR CONDUCTING FATIGUE ASSESSMENTS
Licensees shall ensure that fatigue assessments are applicable for all individuals in the FFD
Program under the following conditions and are conducted by personnel trained in accordance
with NEI 03-04.
a. For-cause. In addition to any other test or determination of fitness that may be required, a
fatigue assessment must be conducted in response to an observed condition of impaired
individual alertness creating a reasonable suspicion that an individual is not fit to safely
and competently perform his or her duties, except if the condition is observed during an
individual's break period. If the observed condition is impaired alertness with no other
behaviors or physical conditions creating a reasonable suspicion of possible substance
abuse, then the licensee need only conduct a fatigue assessment. If the licensee has reason
to believe that the observed condition is not due to fatigue, the licensee need not conduct
a fatigue assessment.
b. Self-declaration. A fatigue assessment must be conducted in response to an individual's

self-declaration to his or her supervisor that he or she is not fit to safely and competently
perform his or her duties for any part of a working tour because of fatigue, except if,
following the self-declaration, the licensee permits or requires the individual to take a
break of at least 10 hours before the individual returns to duty;
c. Post-event. A fatigue assessment must be conducted in response to events requiring post-

event drug and alcohol testing. Licensees may not delay necessary medical treatment in
order to conduct a fatigue assessment; and
d. Follow-up. If a fatigue assessment was conducted for cause or in response to a self-

declaration, and the licensee returns the individual to duty following a break of less than
10 hours in duration, the licensee shall reassess the individual for fatigue as well as the
need to implement controls and conditions before permitting the individual to resume
performing any duties. If no break occurs, only one assessment is required.
44
October 2008
12.2 INDIVIDUALS CONDUCTING FATIGUE ASSESSMENTS
Either a supervisor or a staff member of the FFD program, who is trained, shall conduct the
fatigue assessment face to face with the individual whose alertness may be impaired.
a. In the case of a fatigue assessment conducted for cause, the individual who observed the
condition of impaired alertness may not conduct the fatigue assessment.
b. In the case of a post-event fatigue assessment, the individual who conducts the fatigue
assessment may not have
(i) Performed or directed (on-site) the work activities during which the event occurred;
(ii) Performed, within 24 hours before the event occurred, a fatigue assessment of the
individuals who were performing or directing (on-site) the work activities during which
the event occurred; and
(iii) Evaluated or approved a waiver of the limits for any of the individuals who were
performing or directing (on-site) the work activities during which the event occurred, if
the event occurred while such individuals were performing work under that waiver.
12.3 REQUIRED INFORMATION
A fatigue assessment must provide the information necessary for management decisions and
actions in response to the circumstance that initiated the assessment.
a. At a minimum, the fatigue assessment must address the following factors:
(i) Acute fatigue;
(ii) Cumulative fatigue; and
(iii) Circadian variations in alertness and performance.
b. Individuals shall provide complete and accurate information that may be required by the
licensee to address the required factors. Licensees shall limit any inquiries to only the
personal information from the subject individual that may be necessary to assess the
required factors
c. Review of individual performance as applicable.
45
October 2008
12.4 ASSESSMENT AND ACTIONS
a. The licensee may not conclude that fatigue has not or will not degrade the individual's
ability to safely and competently perform his or her duties solely on the basis that the
individual's work hours have not exceeded any of the work hour limits or that the
individual has had the minimum breaks or minimum days off, as applicable.
b. Following a fatigue assessment, the licensee shall determine and implement the controls
and conditions, if any, which are necessary to permit the individual to resume performing
duties for the licensee, including the need for a break.
12.5 DOCUMENTATION
a. Licensees shall document the results of any fatigue assessments conducted, the
circumstances that necessitated the fatigue assessment, and any controls and conditions
that were implemented.
b. The licensee shall maintain on-site a summary for each nuclear power plant site of
instances of fatigue assessments that were conducted during the previous calendar year
for any individual identified in § 26.4(a) through (c). The summary shall include:
* The conditions under which each fatigue assessment was conducted (i.e., self-
declaration, for cause, post-event, followup).
0 A statement of whether or not the individual was working on outage activities at the
time of the self-declaration or condition resulting in the fatigue assessment.
* The category of duties the individual was performing, if the individual was
performing the duties described in § 26.4(a)(1) through (a)(5) at the time of the self-
declaration or condition resulting in the fatigue assessment.
* The management actions, if any, resulting from each fatigue assessment.
46
October 2008
12.6 ASSESSMENT PROCESS
A fatigue assessment is evaluating an individual's ability to perform any assigned duties within
the scope of the fitness-for-duty rule. It is not limited to covered individuals.
The process for conducting a fatigue assessment includes the following steps:
1. Identification of condition requiring a fatigue assessment:
* Name of the individual.

* Date and time.
* Type of evaluation: For-Cause, Self-declaration, Post-event, Follow-up
* Narrative supporting the type of evaluation
* For Cause--description of observed behavior
* Self-declaration--description of current job duties, time in a duty status, and
scheduled end of tour.
* Post-event--describe the event and the individuals involvement.
* Follow-up--length of rest period, reason for early return, and expected duties
* Name, date, time, signature of individual completing this section.
2. Assessment
* Work history for past 14 days as reported by the individual.

* Work history for the past 14 days as documented by the licensee.
* Statement that the following were considered:
" Potential for acute fatigue-time since last 10 hour break.
* Potential for cumulative fatigue-review work history above. Determine if the
individual has had the opportunity for two restorative rest periods, 34 hours off in
the last 7 days.
* Circadian factors-time of day and recent work cycle.
* Observation and statements of the individual.
" Nature of work to be performed.
* Results of evaluation
* Individual is fit for duty-return to full work status.
* Individual is not fit for duty due to fatigue-provide a 10 hour break.
* Individual is returned to duties with the following restrictions (Describe the
restrictions. Restrictions can include assignment to non-covered work, a nap
before continuing covered work, etc.)
* Name, date, signature of supervisor.
47
October 2008
13 SELF-DECLARATIONS
It is the individual's responsibility to make a clear self-declaration of fatigue. Site procedures

should clearly identify how a self-declaration is to be made and leave no room for confusion. A
casual statement to a supervisor or fellow employee that anindividual is tired is not a self-
declaration. The process shall leave no confusion that a declaration was made and when it was
made. It should also be clear that an assessment is not needed if the supervisor agrees with the
individual and provides a rest break of at least 10 hours.
Any individual covered by the FFD program can self declare.
Self-declarationsduring extended work hours.
If an individual is performing, or being assessed for, work under a waiver of the requirements
and declares that, due to fatigue, he or she is unable to safely and competently perform his or her
duties, 'the licensee shall immediately stop the individual from performing any covered work,
except if the individual is required to continue performing those duties under other requirements
of the regulations, e.g., meet minimum licensed operator staffing. if the subject individual must
continue performing the covered work until relieved, the licensee shall immediately take action
to relieve the individual. Following the self-declaration or relief from performing covered work,
as applicable, the licensee:
* May reassign the individual to duties other than covered work, but only if the results of a
fatigue assessment indicate that the individual is fit to safely and competently perform
those other duties;
" Shall permit or require the individual to take a break of at least 10 hours before the
individual returns to performing any covered work.
48
October 2008
14 TRAINING AND EXAMINATION
Reference: 10 CFR Part 26.203(c)
Licensees shall add the following KAs to the content of the training that is required in § 26.29(a)
and the comprehensive examination required in § 26.29(b):
* Knowledge of the contributors to worker fatigue, circadian variations in alertness and

performance, indications and risk factors for common sleep disorders, shift work
strategies for obtaining adequate rest, and the effective use of fatigue countermeasures.
* Ability to identify symptoms of worker fatigue and contributors to decreased alertness in
the workplace.
This section describes the level of training to meet the requirements of 10 CFR 26 Subpart I.
The KA's and objectives are further defined in NEI 03-04.
Employees and contractors of the licensee should be aware of the trustworthiness and reliability
requirements for unescorted access to the protected area, the importance of being fit for duty,
understand the potential consequences of working while fatigued, and work in compliance with
the station FFD policy.
The specific training objectives relating to the fatigue KA's are implemented within NEI 03-04
and should ensure the workers are able to:
* Demonstrate knowledge of the basic fatigue management requirements for workers.

* Recognize the personal, public health, and safety hazards associated with fatigue.
* Discuss the company fatigue management policy.
* Discuss individual roles and responsibilities under the company fatigue management
policy.
* Demonstrate knowledge of the contributors to worker fatigue, circadian variations in
alertness and performance, indications and risk factors for common sleep disorders, shift
work strategies for obtaining adequate rest, and the effective use of fatigue
countermeasures.
* Demonstrate understanding of identifying symptoms of worker fatigue and contributors
to decreased alertness in the workplace.
* Demonstrate understanding of fatigue management techniques.
* Discuss the methods used to implement the company fatigue management policy.
" Discuss th'e consequences of not following the company fatigue management policy.
" Discuss individual and company rights regarding the company fatigue management
policy.
49
October 2008
15 REVIEWS
Reference: 10 CFR Part 26.205(e)
Licensees shall evaluate the effectiveness of their control of work hours of individuals who are
subject to this section. At a minimum, licensees shall conduct the reviews once per calendar year.
If any plant or security system outages or increased threat conditions occurred since the licensee
completed the most recent review, the licensee shall include in the subsequent review an
evaluation of the control of work hours during the outages or increased threat conditions.
Licensees shall complete the review within 30 days of the end of the review period. The review
period should be defined by the licensee.
Licensees shall:
1. Review the actual work hours of covered individuals for consistency with work hours
scheduling requirement objective of preventing impairment from fatigue due to duration,
frequency, and sequencing of hours worked. The review should be based on information
associated with fatigue including but not limited to the corrective action program. At a
minimum, this review should address:
a. Individuals whose actual hours worked during the review period exceeded an average
of 54 hours per week in any shift cycle while the individuals' work hours .are subject
to the non-outage days off requirements.
b. Individuals who were granted more than one waiver during the review period.
c. Individuals who were assessed for fatigue during the review period.
2. Review the worker performance of covered individuals for consistency with work hours
scheduling requirement objective of preventing impairment from fatigue due to duration,
frequency, and sequencing of hours worked. The review should be based on information
associated with fatigue including but not limited to the corrective action program. At a
minimum, this review should address:
a. Individuals whose actual hours worked during the review period exceeded an average
of 54 hours per week in any shift cycle while the individuals' work hours are subject
to the non-outage days off requirements.
b. Individuals who were granted more than one waiver during the review period.
c. Individuals who were assessed for fatigue during the review period.
3. Review individuals' hours worked and the waivers under 'which work was performed to
evaluate staffing adequacy for all jobs subject to the work hour controls.
50
October 2008
4. Review performance of the station in adhering to work schedules for covered work
groups: evaluate whether or not the schedule is effectively being implemented.
a. Is the schedule being adhered to?
b. Are the changes understood and reasonably consistent with a properly managed
schedule?
c. Does the overtime utilized support efficient utilization of resources?
d. Are the available resources properly aligned with the scheduled work load?
e. Is unplanned work or outages indicative that other corrective actions are necessary?
f. Does the level and pattern of overtime support a determination that staff size is
appropriate for the schedule and work
5. Document the methods used to conduct these reviews and the results of the reviews.
6. Record, trend, and correct, under the licensee's corrective action program, any problems
identified in maintaining control of work hours consistent with the specific requirements
and performance objectives of the rule.
51
October 2008
16 RECORDS
Reference: 10 CFR Part 26.203(d)
Licensees shall retain the following records for at least three years or until the completion of all
related legal proceedings, whichever is later:
* Records of work hours for individuals who are subject to the work hour controls
" Records of shift schedules and shift cycles of individuals who are subject to the work
hour controls
* The documentation of waivers including the bases for granting the waivers
" The documentation of work hour reviews
* The documentation of fatigue assessments
52
October 2008
17 REPORTING
Reference: 10 CFR Part 26.203(e)
Licensees shall include the following information in a standard format in the annual FFD
program performance report required under § 26.717:
A summary for each nuclear power plant site of all instances during the previous calendar
year in which the licensee waived the work hour controls specified in § 26.205(d)(1) through
(d)(4) for individuals described in § 26.4(a). The summary shall include only those waivers
under which work was performed. If it was necessary to waive more than one work hour
control during any single extended work period, the summary of instances shall include each
of the work hour controls that were waived during the period. For each category of
individuals specified in § 26.4(a), the licensee shall report:
a. The number of instances in which each work hour control specified in

§ 26.205(d)(1)(i) through (d)(1)(iii), (d)(2)(i) and (d)(2)(ii), and (d)(3)(i) through
(d)(3)(v) was waived for individuals not working on outage activities.
b. The number of instances in which each work hour control specified in

§ 26.205(d)(1)(i) through (d)(1)(iii), (d)(2)(i) and (d)(2)(ii), (d)(3)(i) through
(d)(3)(v), and (d)(4) and (d)(5)(i) was waived for individuals working on outage
activities.
c. A summary that shows the distribution of waiver use among the individuals within
each category of individuals identified in § 26.4(a) (e.g., a table that shows the
number of individuals that received only one waiver during the reporting period, the
number of individuals that received a total of two waivers during the reporting period,
etc.).
d. A summary of corrective actions, if any, resulting from the analyses of these data,
including fatigue assessments.
Reports related to fatigue management can be integrated into the overall FFD report and can be
submitted electronically.
53
October 2008
18 AUDITS
Reference: 10 CFR Part 26.203(f)
Licensees shall audit the management of worker fatigue as required by § 26.41.
Conduct of audits. Audits shall focus on the effectiveness of the FFD program element, Fatigue
Management, and shall be conducted by individuals who are qualified in the subject(s) being
audited. The individuals performing the audit of the program shall be independent from both the
subject FFD program's management and from personnel who are directly responsible for
implementing the FFD program.
Audit results. The result of the audits, along with any recommendations, shall be documented
and reported to senior corporate and site management. Each audit report shall identify conditions
that are adverse to the proper performance of the FFD program, the cause of the condition(s),
and, when appropriate, recommended corrective actions. The licensee or other entity shall review
the audit findings and take corrective actions, including re-auditing of the deficient areas where
indicated, to preclude, within reason, repetition of the condition. The resolution of the audit
findings and corrective actions shall be documented.
Timing of Audits. Audits shall be conducted each twenty four months in accordance with the
license's audit program.
54

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NEI 06-11 [Revision 1]

Nuclear Energy Institute

Joseph Bauer Exelon

Maintaining reasonable assurance of industrial and nuclear safety

2 PURPOSE AND APPLICABILITY ...................................... 2

2.1 PURPOSE ..................................................................................................................... 2

4 IM PLEM ENTATION ..................................................................................................... 8

5 POLICY AND PROCEDURES .................................................................................. 9

6.1 INDIVIDUALS SUBJECT TO FATIGUE MANAGEMENT ................................................... 12

7.1 PERIODIC O VERTIME ............................................................................................... 19

8.1 CALCULATING H OURS W ORKED ................................................................................. 24

10 PERSONNEL ACTIONS ......................................................................................... 42

12 FATIGUE ASSESSMENTS................ ............................ 44

12.1 CONDITIONS FOR CONDUCTING FATIGUE ASSESSMENTS ......................................... 44

14 TRAINING AND EXAM INATION ............................................................................ 49

15 REVIEW S ............................................................... I............................................ 50

MANAGING PERSONNEL FATIGUE AT NUCLEAR POWER

2 PURPOSE AND APPLICABILITY

Reference: . 10 CFR Part 26.20 1, "Applicability"

2.2.2 Work Hour Controls for Covered Individuals

Reference: 10 CFR Part 26.5

The following definitions are used in this guide.

Alertness means the ability to remain awake and sustain attention.

Covered work means the following:

Off-site means any area not considered on-site.

Maintenance means, the following onsite maintenance activities: Modification, surveillance,

" sShift turnover time.

Work hour controls mean the regulatory requirements in 10 CFR 26.205.

5 POLICY AND PROCEDURES

Reference: 10 CFR Part 26.203 General Provisions

1. Address the affect of fatigue on FFD;

The licensee shall develop, implement, and maintain procedures that:

* Determining that a work hour waiver is necessary to mitigate or prevent a

3. The IGeneral Manager, Plant Operationsi is responsible for:

5. Each lDepartment Headi is responsible for:

6 INDIVIDUALS SUBJECT TO FATIGUE MANAGEMENT AND WORK HOUR

Reference: 10 CFR Part 26.4 "FFD Program Applicability to Categories of Individuals"

6.1 INDIVIDUALS SUBJECT TO FATIGUE MANAGEMENT

6.2 WORK HOUR CONTROLS FOR COVERED INDIVIDUALS

* Maintenance activities on systems, structure and components that are off-site.

* Note: At times an activity requires starting or stopping a piece of equipment. The

If an unbadged contractor is brought on-site to do emergent critical specialty work on a risk-

A risk significant component is removed from on-site to be refurbished or repaired. Is the

" Is the individual on-site?

(See the following flow chart.)

Is the work activity an operations or

Is the work activity on a risks gnificant NO- I

'Is the individual direictlyinvolved

Y 2IS the individual making technical

The following tasks are examples generally considered NOT directing:

" Engineering tasks

Answer: The System Engineer is providing information to the supervisor of a maintenance

7 WORK HOURS SCHEDULING

Work Hour Scheduling

" Duration of scheduled work period (not to exceed 12 hours)

7.1 PERIODIC OVERTIME

The.use of Periodic Overtime shall be evaluated by plant management on a quarterly basis as

7.2 TRANSITIONS BETWEEN SCHEDULES

7.3 TRANSITIONING ONTO A SHIFT OR BETWEEN COVERED GROUPS OR INTO A COVERED