The inspectors identified that the licensee was inconsistent in the application of station requirements for evaluating human performance circumstances. Administrative Control Procedure (
ACP) 114.5, Action Request System, required that all human performance circumstances be investigated either by root cause analysis, fact finding meetings, or completion of fact finding questionnaires (FFQ). The inspectors identified approximately 17 examples (out of the population of 50 human performance circumstance
ARs reviewed) where the licensee did not perform a root cause analysis, fact finding meeting, or FFQ and did not provide documentation in the
AR to justify why a root cause analysis, fact finding meeting, or FFQ was not completed. The failure to perform a root cause analysis, fact finding meeting, FFQ, or provide justification in the
AR was considered to be a violation of
10 CFR 50, Appendix B, Criterion V, Instructions, Procedures and Drawings. However, due to its very low safety significance and because the finding has been entered into your corrective action program, the NRC is treating this issue as a Non-Cited Violation.
The inspectors performed a risk significance screening of this finding in accordance with NRC Inspection Manual Chapter 0610*, Power Reactor Inspection Reports, Appendix B, Thresholds for Documentation. Because the failure to document the human performance circumstance evaluation as required did not have an actual or credible impact on safety, the issue was not evaluated using
NRC Manual Chapter 0609,
Significance Determination Process. However, the finding was more than minor based on extenuating circumstances (Group 3 Questions). The finding was considered to be a substantive cross-cutting issue because the issue was captured in a number of examples noted in the different functional areas examined during the inspection and across plant departments which indicated an adverse performance pattern.
