The inspectors identified a
Severity Level IV Non-Cited Violation of
Technical Specification 5.2.2.d for not properly implementing and maintaining procedures for controlling plant staff work hours of personnel performing safety-related activities. Procedure
LS-AA-119, Overtime Controls, Revision 4, was deficient in that it permitted the plant manager to authorize work-hour deviations for routine refueling outage activities. This issue has a cross-cutting aspect in the area of Human Performance, Resources (Item H.2.(c) of
IMC 0305), because Procedure
LS-AA-119 did not provide adequate instructions to provide reasonable assurance that station management would properly control overtime for plant staff performing safety-related functions to assure nuclear safety as required by
Technical Specification 5.2.2.d. The violation is more than minor because, if left uncorrected, the excessive work hours would increase the likelihood of human errors during refueling outage activities and response to plant events and would become a more significant safety concern. The finding is not suitable for
Significance Determination Process evaluation, but has been reviewed by NRC management in accordance with
IMC 0609, Appendix M,
Significance Determination Process Using Qualitative Criteria. The resulting increased likelihood of human error, would adversely affect the stations defense-in-depth. However, management determined the violation 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. The licensee added this issue to their corrective action program to address correcting the procedure. In accordance with the
NRC Enforcement Policy, Supplement I.D, the issue, being evaluated as having very low safety significance by the
Significance Determination Process, is a
Severity Level IV Violation.
