05000293/FIN-2013008-01
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Finding | |
|---|---|
| Title | Inappropriate Fatigue Rule Waivers |
| Description | The inspectors identified a Green non-cited violation of 10 CFR 26.207(a) for Entergys failure to issue waivers that were necessary to mitigate or prevent conditions adverse to safety, and only to address circumstances that could not have been reasonably controlled. Specifically, Entergy issued multiple fatigue waivers during planned and forced outages that were determined to be inappropriate based on plant conditions. Additionally, the inspectors identified other waivers of the fatigue rule that Entergy issued during nonoutage periods that were inappropriate based on plant conditions. Entergys immediate corrective action was to enter this issue into their corrective action program as condition reports CR-PNP-2013-06706 and CR-PNP-2013-06707 for further evaluation. The inspectors determined that Entergys failure to grant waivers in accordance with regulatory requirements was a performance deficiency that was within Entergys ability to foresee and correct. This performance deficiency is more than minor because it was associated with the human performance attribute of the Initiating Events cornerstone and adversely affected the cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, the resulting increased likelihood of human error could adversely affect the station\'s defense-in-depth. Additionally, the finding was similar to IMC 0612, Appendix E, Examples of Minor Issues, Example 9.a and is 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 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 finding has a cross-cutting aspect in the area of Problem Identification and Resolution, Corrective Action Program, because Entergy did not thoroughly evaluate problems such that the resolutions address causes and extent conditions. Specifically, Entergy previously identified that waivers were inappropriately granted for conditions that were not necessary to mitigate or prevent conditions adverse to safety. However, because the previous evaluations were limited in scope and focus, Entergy did not develop corrective actions to address the deficient condition. |
| Site: | Pilgrim |
|---|---|
| Report | IR 05000293/2013008 Section 4OA2 |
| Date counted | Dec 31, 2013 (2013Q4) |
| Type: | NCV: Green |
| cornerstone | Initiating Events |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71152 |
| Inspectors (proximate) | J Ayala R Mckinley J Bream E Keighley |
| Violation of: | 10 CFR 26.207 |
| CCA | P.2, Evaluation |
| INPO aspect | PI.2 |
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Finding - Pilgrim - IR 05000293/2013008 | |||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Pilgrim) @ 2013Q4
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