05000387/FIN-2013008-01
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Finding | |
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Title | Failure to Restrict Operators from Performing Licensed Duties with Medically Disqualifying Conditions and Failure to Notify the NRC within 30 Days of Discovering Changes in Medical Conditions |
Description | The inspectors identified: 1) an apparent violation (AV) of Title 10 of the Code of Federal Regulations (10 CFR) 55.21, Medical Examination; Part 55.25 Incapacitation because of disability or illness; Part 55.33, Disposition of an Initial Application, for the failure of the licensee to restrict operators from performing licensed duties when they had disqualifying medical conditions; and 10 CFR 50.74, Notification of change in operator or senior operator status, for PPLs failure to notify the NRC within 30 days of changes in licensed operators medical conditions; and, 2) a related finding of very low safety significance (Green) for PPLs failure to implement effective corrective actions to prevent this recurring AV. Specifically, the inspectors identified that four licensed operators developed disqualifying medical conditions that were not properly evaluated by PPL staff in accordance with ANSI/ANS-3.4-1983, American National Standard Medical Certification and Monitoring of Personnel Requiring Operator Licenses for Nuclear Power Plants. Additionally, PPL did not restrict the operators from performing licensed duties or obtain NRC approval (by requesting conditioned licenses) to continue to perform licensed duties, which caused the operators to not meet the requirements of 10 CFR 55.33(a)(1). Additionally, the inspectors identified eight instances in which PPL failed to notify the NRC within 30 days of learning of changes in licensed operator medical conditions that involved permanent disabilities/illnesses as required by 10 CFR 50.74. This resulted in the operators performing licensed operator duties without properly restricted licenses. PPL has taken actions to correct these issues by formally notifying the NRC and requesting conditioned licenses, as necessary, training the licensed operators and medical staff in the applicable requirements, and revising related procedures to provide additional guidance and require annual training. PPL entered this issue into their corrective action program. (CR-1709539) The inspectors reviewed this issue in accordance with NRC IMC 0612, Appendix B, Issue Screening for traditional enforcement and as part of the Reactor Oversight process (ROP). Under the ROP, the inspectors also identified a related finding of very low safety significance (Green) involving PPLs failure to prevent this recurring AV. Traditional Enforcement Basis for AV: The inspectors determined that PPLs failure to ensure that licensed operators met the license conditions associated with minimum medical qualifications prior to performing license activities and failure to notify the NRC of the changes within 30 days was a performance deficiency that was within PPL\\\'s ability to foresee and correct and should have been prevented. Specifically, the inspectors determined that four operators with disqualifying medical conditions continued to stand watch in the control room. Additionally, the NRC identified eight instances where changes occurred in licensee medical conditions that involved permanent disabilities and/or illnesses but were not reported within 30 days as required. The inspectors determined that Traditional Enforcement (TE) applies because the issue impacted the NRC\\\'s ability to perform its regulatory function. Namely, the NRC relies upon PPL to ensure all licensed operators meet the medical conditions of their licenses. 10 CFR 55.25 requires that if, during the term of the individual operator license, the operator develops a permanent physical or mental disability that causes the operator to fail to meet the requirements of 55.21 of this part, the facility licensee shall notify the Commission, within 30 days of learning of the diagnosis, in accordance with 10 CFR 50.74(c). PPL failed to properly identify that operators had disqualifying medical conditions and also did not restrict the operators from performing licensed duties. These issues are being characterized as an apparent violation in accordance with the NRCs Enforcement Policy, and its final significance will be dispositioned in separate future correspondence. (Section 4OA2.1) ROP Green Finding Basis: Since 2008, PPL has been issued three Severity Level (SL) IV violations and one SL III violation related to the medical qualifications of their licensed operators. PPL procedure, NDAP-QA-0702, ACTION REQUEST AND CONDITION REPORT PROCESS, Revision 39, defines a Significant Condition Adverse to Quality (SCAQ) as a condition determined to be significant enough to warrant a root cause analysis and actions to prevent recurrence. (For significant conditions adverse to quality, the causes of the deficiency shall be determined and corrective actions shall be taken to preclude recurrence). NDAP-QA-0702 Attachment M, lists a Severity Level III or greater NRC Notice of Violation (NOV), as an example of a SCAQ. Following the 2009 SL III NOV, PPL failed to identify the causes of the condition that led to the SCAQ, and the extent of cause and condition reviews were ineffective to identify additional issues. The inspectors determined that PPLs failure to implement adequate corrective actions to prevent this recurrence in response to these previous violations was an associated performance deficiency that was within PPL\\\'s ability to foresee and correct and should have been prevented. The performance deficiency is more than minor because, if left uncorrected, having operators stand watch with disqualifying medical conditions has the potential to lead to a more significant safety concern. The inspectors evaluated this finding using IMC 0609, Attachment 4, Initial Characterization of Findings, and IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, Exhibit 2, Mitigating Systems Screening Questions. All questions in Exhibit 2 were answered no and therefore this associated finding was determined to be of very low safety significance (Green). This issue is indicative of current performance and is determined to have a cross-cutting issue in the area of Problem Identification and Resolution - Evaluation P.1(c), related to thorough evaluation of problems. Specifically, PPLs reviews following the issuance of similar violations in 2009 and 2011, did not identify the additional cases discovered in 2012, and PPLs root cause evaluation completed in 2012, did not identify a root and several contributing causes, which were subsequently identified by the NRC inspectors. |
Site: | Susquehanna |
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Report | IR 05000387/2013008 Section 4OA2 |
Date counted | Jun 30, 2013 (2013Q2) |
Type: | Finding: Green |
cornerstone | Mitigating Systems |
Identified by: | NRC identified |
Inspection Procedure: | IP 71152 |
Inspectors (proximate) | C Miller J Caruso T Hedigana Turilinb Smith D Dodson F Arner F Bower J Grieves S Hansell T Daun T Hedigan |
INPO aspect | |
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Finding - Susquehanna - IR 05000387/2013008 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Susquehanna) @ 2013Q2
Self-Identified List (Susquehanna)
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