05000416/FIN-2012003-07
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Finding | |
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| Title | Inappropriate Use of Waivers to Allow Workers to Exceed the Minimum Day Off Rule |
| Description | The inspectors identified a non-cited violation of 10 CFR 26, Subpart I, Managing Fatigue, Subsection 207, Waivers and Exceptions, when the licensee inappropriately used waivers to allow workers to exceed the minimum day off rule. While reviewing condition reports, the inspectors noted the use of work hour waivers for a large number of staff. The circumstances for the use of waivers were the refueling outage lasting more than 60 days, contract expiration leading to 14 layoffs, and the loss of 4 workers via voluntary resignation. Due to these circumstances, work hours and fatigue of waivered individuals would have to be assessed daily. The assessment is required because the work hour limit of these individuals exceeded the minimum day off rule, therefore requiring daily monitoring until the end of the cycle. The waivered individuals averaged two days off per six-week period compared to the required three days off. Title 10 CFR 26.207 (a)(2) allows the granting of waivers only to address circumstances that could not have been reasonably controlled. The inspectors determined that the licensee was aware of the circumstances of an extended refueling outage and contract renewal deadline well in advance of the need to grant waivers, and a reasonable amount of time was available for the licensee to develop and execute contingency plans to negate the need to use waivers. Corrective actions included initiating assessments and waivers for exceeding minimum days off requirements for shift personnel for the six-week period ending May 27, 2012, and returning to the normal on-line work schedule in which adequate manpower is available to meet the requirements of the rule. The licensee entered this issue into the corrective action program as Condition Report CR-GGN-2012-7348. The finding is more than minor because it is associated with the access authorization attribute of the Security Cornerstone, and affected the cornerstone objective to provide assurance that the licensees security system and material control and accounting program use a defense in-depth approach and can protect against (1) the design basis threat of radiological sabotage from external and internal threats, and (2) the theft or loss of radiological materials. Using the Inspection Manual Chapter 0609, Appendix E, Baseline Security Significance Determination Process for Power Reactors, Figures 5 and 6, the finding was determined to have very low security significance because the calculated point total did not exceed the threshold value for a Green non-cited violation. The cumulative total for this finding was zero points, which was calculated by factoring the one impact area (vital areas) against Tier III Element 08.02.08, security force work hours, of the access authorization attribute, which resulted in a total of zero points within this attribute. The finding was determined to have a cross-cutting aspect in the area of human performance associated with the decision making component in that the licensee failed to use conservative assumptions in developing staff schedules for the duration of refueling outage 18 and for allowing an employment contract to expire that led to 14 individuals being laid off without realizing the impact these decisions would have on the licensees ability to meet the requirements of the rule. |
| Site: | Grand Gulf  |
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| Report | IR 05000416/2012003 Section 1R20 |
| Date counted | Jun 30, 2012 (2012Q2) |
| Type: | NCV: Green |
| cornerstone | Miscellaneous |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.2 |
| Inspectors (proximate) | R Smith A Barrett J Laughlin V Gaddy G Apger A Fairbanks B Rice J Braisted R Kumana |
| CCA | H.14, Conservative Bias |
| INPO aspect | DM.2 |
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Finding - Grand Gulf - IR 05000416/2012003 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Grand Gulf) @ 2012Q2
Self-Identified List (Grand Gulf)
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