Severity Level IV. The inspectors identified a
Severity Level IV NCV of
TS 6.8.1.j for not properly implementing and maintaining procedures for controlling plant staff work hours of personnel performing safety-related activities. Procedure
LS-AA-119, Overtime Controls, was deficient in that it permitted the plant manager to authorize work-hour deviations for routine refueling outage activities. Consequently, the plant manager authorized over 700 personnel to work greater than
72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and up to
84 hours9.722222e-4 days <br />0.0233 hours <br />1.388889e-4 weeks <br />3.1962e-5 months <br /> per 7-day period for routine outage support activities during the
TMI refueling outage (1R17), which exceeded the TS requirements. The affected workers included reactor operators, senior reactor operators, auxiliary operators, health physicists, key maintenance personnel, emergency response organization members, reactor engineers supporting reactivity manipulations and fuel handling, and engineering and professional personnel performing safety-related work. The licensee entered this issue into their corrective action program (IR 713257). Changing implementing procedure,
LS-AA-119, so that it no longer complies with the facility technical specification for controlling the plant staff overtime has the potential to impact the NRCs ability to perform its regulatory function. The violation affected the
Mitigating Systems cornerstone and is more than minor because, if left uncorrected, the excessive work hours would increase the likelihood of human errors during refueling outage activities and response to plant events. This violation is characterized as a
Severity Level IV in accordance with the
NRC Enforcement Policy. This issue has a cross-cutting aspect in the area of Human Performance, because procedure
LS-AA-119 did not provide adequate instructions to provide reasonable assurance that station management would properly control overtime for plant staff performing safety-related functions
H.2(c). (Section 1R20
