The inspectors identified a non-cited violation of
Technical Specification (TS) 6.2.2.d, Unit Staff, because four individuals worked beyond the TS limit of
72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in a 7-day period without proper authorization. Additionally,
PSEG did not approve the work hour deviations of 20 individuals prior to them working the hours.
PSEG entered this issue into their corrective action program in notification 20357323. The finding was determined to be more than minor because, if left uncorrected, exceeding TS work hour limits would increase the likelihood of a fatigue-related human performance error during normal plant operations or plant events. The inspectors used
Inspection Manual Chapter 0609 Appendix M, \\\\\\\"
Significance Determination Process Using Qualitative Criteria,\\\\\\\" because other
significance determination process guidance was not suited to provide reasonable estimates of the significance of this inspection finding. With the assistance of Region 1 management and a Senior Risk Analyst, the inspectors determined that the finding was of very low safety significance (Green) because there were no human performance issues that were linked directly to worker fatigue. The finding had a cross-cutting aspect in the area of human performance because
PSEG did not follow procedure
LS-AA-119 to authorize deviations from working hour limits described in
Technical Specification 6.2.2.d. (
H.4(b)) (Section 4OA5
