2010/11/04-Comment (4) of Joseph Richardson on FR Doc # 2010-26715

Document ID: NRC-2010-0304-0006
Document Type: Public Submission
Agency: Nuclear Regulatory Commission
Received Date: November 03 2010, at 12:00 AM Eastern Daylight Time
Date Posted: November 16 2010, at 12:00 AM Eastern Standard Time
Comment Start Date: October 22 2010, at 12:00 AM Eastern Standard Time
Comment Due Date: January 5 2011, at 11:59 PM Eastern Standard Time
Tracking Number: 80b80245
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As an Equipment Operator (EO), I have been directly affected by the Work Hour Rules. The minimum day off requirement which has been proposed to be removed has been both a blessing and a problem. During an outage having a day or two days off in a row after working 5 or 6 straight days of 12 hour shifts is nice--if you have elected to work the day shift. During your time off you can relax with family, go to appointments, do necessary shopping, and generally take care of things which can generally only be done during daylight hours. If you have elected to work the night shift and you get a night off, what do you do with your time? If you have a family do you stay up all night quitely watching movies while your family sleeps in the next room? Do you go drinking all night (which does not help one to return to work refreshed)? Perhaps the thing to do is get some exercise--perhaps a midnight jog along the highway which is a little ridiculous. Perhaps what you do with your night off is to go to sleep which makes sense if you are married--except that it does not make sense because you need to sleep during the day to be alert at night. The point is when it comes to working night shift during an outage I would rather stay at work than be forced to stay home. At least at work you are in a safe environment, you can stay active (which is important in keeping your sleep cycle in synch with night shift). What would be nice is be able to go to work 4 hours late 3 nights out of 15. At least that way you can spend some time with family or get a little shopping done late in the afternoon. Doing this will preserve the small amount of benifit afforded the night shift workers under the current rules while improving at work performance because sleep cycles will not be changed from being away from work. This will also address some of the arguments made in the proposal--some workers working second jobs for more money etc., because they will get more overtime on night shift.

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