Publication
The NRC Responds to Nuclear Plant Work-Hour Concerns Prompted by COVID-19
By Kelly A. Daly
The Nuclear Regulatory Commission announced that it is prepared to grant temporary exemptions from work-hour controls when the COVID-19 virus adversely impacts staffing levels at nuclear plants such that the applicant can no longer meet the work-hour control requirements provided that the applicant can demonstrate that fatigue-management controls are in place. Specifically, applicants can email a request seeking exemption from 10 CFR 26.205(d)(1)-(d)(7) to the facility’s NRC project manager from a senior level licensee manager with decision-making authority (with a copy to the NRC Document Control Desk) with the following information:
- A statement that the licensee can no longer meet the work-hour controls of 10 CFR 26.205(d) for certain positions;
- A list of positions for which the licensee will maintain current work-hour controls under 10 CFR 26.205(d)(1)-(d)(7);
- The date and time when the licensee will begin implementing its site-specific COVID-19 PHE fatigue-management controls for personnel specified in 10 CFR 26.4(a);
- A statement that the licensee’s site-specific COVID-19 PHE fatigue-management controls are consistent with the constraints outlined in this letter and its attachment; and
- A statement that the licensee has established alternative controls for the management of fatigue during the period of the exemption and that at a minimum, the controls ensure that for individuals subject to these alternative controls:
(1) Not more than 16 work hours in any 24-hour period and not more than 86 work-hours in any 7-day period, excluding shift turnover;
(2) A minimum 10-hour break is provided between successive work periods;
(3) 12-hour shifts are limited to not more than 14 consecutive days;
(4) A minimum of six days off are provided in any 30-day period; and
(5) Requirements are established for behavioral observation and self-declaration during the period of the exemption.
The NRC will consider these requests on a case-by-case basis and will act on them within 60-days. Additional information can be found here.
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