Nuclear, Reactors

Implementing the Nuclear Fatigue Rule

Issue 11 and Volume 113.

Working smarter because you can’t work longer

By Keith Cooke, Energy Northwest

Relatively new requirements established by the Nuclear Regulatory Commission in Title 10 of the Code of Federal Regulations—“Fitness for Duty Programs” (10 CFR, Part 26)—ensure employees are fit to safely and competently perform their duties. Similar regulations previously applied mainly to drug and alcohol screening, but the commission recognized that fatigue causes effects similar to consuming drugs and alcohol. In fact, studies show that staying awake for 17 hours straight can have the same effect on a worker’s fitness for duty as having a blood-alcohol level of 0.05. In some states that’s almost too impaired to legally operate a vehicle, so it’s obviously not a good idea for a fatigued person to operate complex equipment at a nuclear plant.

New work rules imposed by federal regulators meant changes for operators at the 1,150 MW Columbia Generating Station in Richland, Wash. Photo Energy Northwest.
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The re-attack on fatigue management regulations was driven by a highly publicized case of fatigued security workers at a U.S. nuclear plant who were videotaped sleeping during a break period in 2007. It certainly was not a welcome event for an industry that has worked hard to maintain and publicize its highly successful safety and security track record. Though the incident involved outsourced personnel, it led the commission to rethink the fatigue rule, as well as the agency’s associated oversight responsibility of all workers at nuclear plants.

The result was the “Subpart 1, ‘Managing Fatigue’” addition to the 10 CFR, Part 26. The regulations in Subpart 1 are extensive and comprehensive, taking into account the multiple causes and effects of worker fatigue. The commission recognized that excessive fatigue results not only from extensive work hours, but also from other causal factors such as stressful working conditions, sleep disorders, accumulation of sleep debt and “the disruptions of circadian rhythms associated with shift work.” The regulations address each of the numerous causal factors. As a result, the nation’s commercial nuclear power plants were hit with an 18-month deadline—Oct. 1, 2009—to implement a complex set of new requirements.

When the new rule was announced, Energy Northwest realized that change was going to require more than just a technology revamp; it was a true game-changer. Energy Northwest operates Columbia Generating Station, a 1,150 MW boiling water reactor that is the only commercially operated nuclear power plant in the Northwest. All of Columbia Generating Station’s power is sold at cost to the Bonneville Power Administration.

Columbia Generating Station was issued a standard 40-year operating license by the Nuclear Regulatory Commission (NRC) in 1983. Energy Northwest is in the process of preparing an application to renew the license for an additional 20 years to 2043. Plans call for this application to be submitted to the NRC in January 2010.

To guide our nuclear fatigue rule (NFR) compliance efforts, we established a steering committee made up of representatives from across the organization, including human resources, training and information services, as well as three major departments affected by the new rule: maintenance, operations and nuclear security. We also included the pros from our health physics and radiation chemistry teams to ensure all bases were covered.

The group’s collective first reaction was that this was going to be a major undertaking and that we would have to work together as an industry to meet the deadline. Fortunately, the Nuclear Energy Institute put together a team of experts and developed a guidance document to help steer the effort.

In the fall of 2008, Energy Northwest used the institute’s guidance document to review software solutions that could facilitate our compliance with the NFR. All major solution providers in the nuclear plant operations management space were coding solutions based on the guidance document. However, coding solutions is only one-third of solving the problem; the rest is modifying the policy procedures and improving the business processes that the solutions are designed to support. As dramatic as the NFR rule change was, there simply was no way that implementing new software was going to get us into compliance.

So we decided to partner with a solution vendor while we wrote the new procedures. This way we could refine our processes and procedures in parallel with and while supporting vendor implementation. We could verify that our new procedures could be enhanced and/or automated via the software and the vendor could reality-check its new features and enhancements to ensure that real-world challenges were effectively addressed.

After carefully reviewing each vendor and associated solution, we decided to work with Ventyx. Ventyx’s domain expertise in the nuclear field demonstrated a track record of success and the company’s eSOMS solution already had an employee qualifications and scheduling module that Ventyx was further enhancing to support NFR. Ventyx was also willing to work closely with us to ensure our requirements were met.

Finding Ways to Work Smarter

We had to overcome many challenges along the way. One, of course, was the complexity of changing the way people work. Before the new rule, you could easily schedule employees to work as long as they were willing to work and still meet the simplistic fatigue management rule. Now, you have to be stringent about scheduling work. Employees can only work so many hours during a work period and so many work periods during a week. The duration of break periods are mandated. You have to maintain consistent start times and a consistent shift rotation. The list of restrictions goes on and on. Obtaining a waiver to exceed work hour restrictions has become so difficult that employees no longer want to pursue a waiver.

The financial challenges associated with these new restrictions are massive. Not only did most plants have to hire additional security officers to follow the new rule, they also had to hire and/or train workers to perform new tasks such as fatigue assessments on fellow employees. And all employees granted unescorted access into the protected area had to be trained to perform fatigue self-assessments. As a result of these new requirements, the average plant had to hire approximately 50 new employees with associated costs reaching into the thousands of dollars—costs you can’t recover with a rate increase.

Workers’ finances were impacted as well. Every nuclear plant has its “overtime zealots” that have gotten comfortable with working hundreds of hours of overtime each year and now they can’t do that.

This was a good example of the change in culture that represented another major challenge. It was a struggle to make people recognize that fatigue is no different than being under the influence of drugs and alcohol. The undertaking became as much, if not more, a cultural and financial project as a software project.

In the end, though, you have no choice. It comes down to the fact that you can’t work longer, you simply have to work smarter. This is an area where the Ventyx software makes a huge impact. The new regulations are complex, making it difficult to meet the financial and operational goals of the company while maintaining regulatory compliance. However, the Ventyx software allows us to take a forward-looking approach using “what if” scheduling scenarios that alert us should any schedule matrix take us out of compliance.

With eSOMS, our schedulers can create baseline schedules and analyze them for NFR violations in real time. They can project schedules six weeks or more out, including both online and outage periods. And, the software will analyze the schedules for NFR compliance incorporating specific group rules, unit operating status, shift cycles, work-hour limits, break periods and minimum days off. The user is alerted to any areas were the baseline schedules are non-compliant so necessary adjustments can be made.

Deviations from the baseline schedules (for example, changes in employees, start/stop times, group associations and so on) can be made before or after the fact and are evaluated for NFR violations. Interfaces to third-party timekeeping systems can be used as validation of actual start/stop times and serve as input when evaluating NFR compliance. Worker replacements for overtime are managed through a controlled call-out process to ensure that replacement employees are both qualified and NFR-compliant. The call-out prioritization process also includes business and labor requirements and tracks the results (for example, refusals/acceptances).

Late in September 2009, Energy Northwest and most of the industry went live with the solution for managing fatigue. The implementation of procedures, templates for evaluating fatigue and the Ventyx solution went smoothly. Strong change management implemented prior to the turn-on date and the pilot program prior to the effective date ensured that all impacted employees could confidently and securely answer, “What’s it mean to me?” This understanding has ensured no issues to date.

Lessons Learned

All the work required to comply with the new rule was a significant challenge to Energy Northwest, as I am sure it was for all organizations. However, we learned some valuable lessons to take forward for future implementations. These lessons include the following:

Get senior management engaged. No big surprise that you would want senior management involved, but note that I use the word “engaged.” You have to help them understand what the issues are from the beginning and help them understand how significant the changes are. Management did not initially believe that we would have to hire 50 people and assess employees’ sleep. We had to take them through the regulations to demonstrate the necessity.

Get to know your employees’ home life. Fatigue assessment is a major challenge that accompanies the new regulation, but it is made easier by understanding what your employees’ lives are like at home. For example, do they have personal commitments that are affecting their sleep cycles? Are they caring for a sick loved one? Working too many hours at work is like having a new baby or a sick loved one at home. So, if you can recognize fatigue from one, you can recognize fatigue from the other.

Allow long timelines for training. At some plants new operators were needed to support the new scheduling requirements. At the high-end of the training scale, the associated educational process requires an 18-month pipeline, including practical training and the NRC exam. In other words, it requires a lot of prior planning. Security officers, on the other hand, require “only” two months of training—but each position in a nuclear site must pass an accredited training program and adequate time must be allowed for the process.

Additional lessons include:

  • New software for new requirements means developing new business processes. Gain input from schedulers during product development to ensure the software’s optimal effectiveness.
  • Schedulers manage multiple processes within the plants. Bringing all of these under one technological roof is daunting, but necessary.
  • Just like software processes, business processes have to be flexible/adaptable to manage unavoidable changes during implementation. Cultural/financial changes are harder to implement, but can achieve dramatic return on investment in the long run.
  • Lay the groundwork by laying out roles and responsibilities from the onset; avoid preconceived notions and don’t make assumptions.

Author: As chief information officer for Energy Northwest, Keith Cooke is responsible for providing leadership to the Information Services Organization, which ensures that information management, policy, technologies and standards are an integral part of the strategic plan and consistent with Energy Northwest business goals. He has extensive experience and expertise in multi-site information technology implementations at nuclear and fossil generation facilities.

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