05000220/FIN-2009010-02
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Finding | |
|---|---|
| Title | Deficient Control of Plant Staff Overtime |
| Description | The inspectors identified a Green NCV of Unit 1 TS 6.2.2.d, Unit Staff, for not properly implementing and maintaining procedures for controlling plant staff work hours of personnel performing safety-related activities. Constellation management authorized over 1000 overtime deviations for personnel to work greater than TS work hour limits for routine outage support activities during NMP Unit 1 outages and other reasons not permitted by TS or NMP Administrative procedures. Constellation received a NCV in July 2008 for deficient control of staff overtime in the Operations Department and repeated the same performance deficiency in the Maintenance Department during the Unit 1 Spring 2009 refueling outage. The licensee entered the issue into their corrective action program. The inspectors determined that failure to properly implement procedures to limit work hours for plant staff performing safety-related functions in accordance with TS 6.2.2.d was a performance deficiency that was reasonably within Constellations ability to foresee and prevent. The finding is more than minor because, if left uncorrected, the excessive work hours could increase the likelihood of human errors during refueling outage activities and response to plant events. The finding was also similar to IMC0612, Appendix E, Examples Minor Issues, example 9a and would be more than minor because this inappropriate use of work hour control waivers was not an isolated incident (e.g., one or two instances). The finding has been reviewed by NRC management in accordance with IMC 0609, Appendix M, Significance Determination Process Using Qualitative Criteria. The resulting increased likelihood of human error could adversely affect the stations defense-in-depth. However, the violation was determined to be of very low significance, because no significant events or human performance issues were directly linked to personnel fatigue as a result of the hours worked. This issue has a cross-cutting aspect in the area of PI&R and the aspect of Corrective Action Program - Evaluation (P.1.C of IMC 0305). The licensee did not thoroughly evaluate problems such that the resolutions address causes and extent of conditions, as necessary. Specifically, an appropriate extent of condition review following the 2008NCV 2008003-04 was not completed and Constellation did not identify that other departments on site (besides Operations) were vulnerable to the performance deficiencies identified and this led to Maintenance repeating many of these same performance deficiencies during the 2009 Unit 1 refueling outage. |
| Site: | Nine Mile Point  |
|---|---|
| Report | IR 05000220/2009010 Section 4OA2 |
| Date counted | Dec 31, 2009 (2009Q4) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71152 |
| Inspectors (proximate) | A Rosebrook D Dempsey M Patel N Lafferty R Powell |
| CCA | P.2, Evaluation |
| INPO aspect | PI.2 |
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Finding - Nine Mile Point - IR 05000220/2009010 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Nine Mile Point) @ 2009Q4
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