ML18050A030

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CFR Part 26 Subpart I - Managing Fatigue, for Period Ending 2017
ML18050A030
Person / Time
Site: Grand Gulf Entergy icon.png
Issue date: 02/19/2018
From: Ellis D
Entergy Operations
To:
Document Control Desk, Office of Nuclear Reactor Regulation, Office of Nuclear Security and Incident Response
References
Download: ML18050A030 (1)


Text

NRC FFD Program Performance Data Reporting System NRC Form 892, Annual Fatigue Reporting Form (EIE General Submission Portal)

Period of Report 10 CFR Part 26, Subpart I - Managing Fatigue Exceeded 16 work hrs in any 24 hr period Daily Work Hours 26.205(d)(1)

Number of Waivers Issued Operating or on-site directing of the operations of systems,as described in 26.4(a)(1)

Operating Outage (days 1-60)

Exceeded 26 work hrs in any 48 hr period Exceeded 72 work hrs in any 7 day period Performing health physics or chemistry duties, as described in 26.4(a)(2)

Operating Outage (days 1-60)

Performing duties of a fire brigade member, as described in 26.4(a)(3)

  • Operating Outage (days 1-60)

Performing maintenance or onsite direction of maintenance, as described in 26.4(a)(4)

Operating Outage (days 1-60)

Performing security duties, as described in 26.4(a)(5)

Operating Outage (days 1-60)

Outage Total (days 1-60)

(Calculated)

Combined Total (Calculated)

Less than 10 hr break b/t successive work periods (or 8 hr break accommodating scheduled transition b/t shifts)

Rest Breaks 26.205(d)(2)

Less than 34 hr break in any 9 day period Minimum Days Off Per Shift Cycle 26.205(d)(3)

Average of less than 1 day off per week for 8-hour shifts Average of less than 2 days off per week for 10-hour shifts Average of less than 2.5 days off per week for 12-hour shifts Average of less than 2 days off per week for 12-hour maintenance shifts Average of less than 3 days off per week for 12-hour security shifts Minimum Days Off for Outage Activities (during first 60 days of outage) 26.205(d)(4) and 26.205(d)(5)

Less than 3 days off per successive 15-day period 26.205.(d)(4)

Less than 1 day off per 7-day period for maintenance personnel 26.205.(d)(4)

Less than 4 days off per successive 15-day period for security personnel 26.205.(d)(5)











Total

  • NOTE: For individuals performing fire brigade duties and other duties, please count them only under the fire brigade column. Do not double count these individuals.

1 Number of Waivers 2

3 Operating or on-site directing of the operations of systems, as described in 26.4(a)(1) 4 5

6 7

8 Performing health physics or chemistry duties as described in 26.4(a)(2)

  • NOTE: For individuals performing fire brigade duties and other duties, please count them only under the fire brigade column. Do not double count these individuals.

9 10 11 - 20 More than 20 Total Employees Issued Waivers (Calculated)

Most Waivers Provided to a Single Individual Number of Employees Issued Waivers

[Note: Even if no waivers were issued for a given column, please enter a value (e.g., 0) in at least one of the cells in the column]

Performing duties of a fire brigade member as described in 26.4(a)(3)

  • Performing maintenance or onsite directing of maintenance as described in 26.4(a)(4)

Performing security duties as described in 26.4(a)(5)

Analysis of Waiver Assessment Data: (Limit 10,000 characters)

Analysis of Fatigue Assessment Data: (Limit 10,000 characters)

Summary and Status of Corrective Actions: (Limit 10,000 characters)

==

Conclusions:==

(Limit 10,000 characters)

Work Hour Controls NRC Form 892 (12/2012)

Was this facility in an outage for any part of the reporting period? (Yes / No)

Did any single site outage last more than 60 days in total? (Yes / No)

Outage Total (after day 60)

(Calculated)

Outage (after day 60)

Outage (after day 60)

Outage (after day 60)

Outage (after day 60)

Outage (after day 60)

Note:

1) Use Adobe Reader 8 or later for this form to work properly.
2) Hold your mouse over a form field to view additional information.

Operating Total (Calculated)

Submission Update - check this box only if this is an update to a previous submission.

Select Facility Person(s) Responsible for Information Provided Company Email Address First Name Position Title Position Title First Name Last Name Last Name Company Email Address Person 1 (required):

Person 2 (optional):

Final Step (Required) - NRC will consider this form authentic in accordance with 26.11 only when the Validate & Lock button has been selected and all errors (i.e., those highlighted in red) have been corrected. The Validate & Lock button will change to Locked after the data validation process has been successfully completed and the form is ready for submission.

Form Locked On:

Did your facility issue any waivers in the reporting period? (Yes / No) 54 hour6.25e-4 days <br />0.015 hours <br />8.928571e-5 weeks <br />2.0547e-5 months <br /> maximum average Alternate to Minimum Days Off 26.205(d)(7)

(Limit 10,000 characters)

APPROVED BY OMB: CLEARANCE NO. 3150-0146



EXPIRES: 11/30/2017 Estimated burden per response to comply with this collection request is 162 hours0.00188 days <br />0.045 hours <br />2.678571e-4 weeks <br />6.1641e-5 months <br />. This form is a voluntary means of reporting the information required under 10 CFR 26.203(e). The information will be used by NRC to evaluate fatigue program performance related to work hour controls and waivers. Send comments regarding burden estimate to the FOIA, Privacy, and Information Collection Branch (T5-F53), U.S. Nuclear Regulatory Commission, Washington DC 20555-0001, or by e-mail to Infocollects.Resource@NRC.gov, and to the Desk Officer, Office of Information and Regulatory Affairs, NEOB-1020, (3150-0146), Office of Management and Budget, Washington DC 20503. If a means used to impose information collection does not display a currently valid OMB control number, the NRC may not conduct or sponsor, and a person is not required to respond to, the information collection.

Annual Fatigue Reporting Form (version 1.5.0 - January 2018)

A review was performed of waivers granted during the assessment period as documented in PCRS. Waivers were granted to complete in-process surveillances, ensure Fire Brigade staffing was met, on-shift Operations ERO staffing was met, and to ensure Security staffing was met during a January 2017 Ice Storm.

The review of the number and circumstances of the waivers performed indicates that the waivers were performed for exigent circumstances, and were not used to bridge gaps in adequate staffing management. This is an appropriate application of the fatigue waiver process. It is therefore concluded that the waiver process was used properly.

Condition Reports (CR) were used to document work hour violations and associated waivers, and all CRs contain information necessary per EN-OM-123. Therefore, no additional corrective actions were warranted, and no follow-up review is needed for any specific department.

No Fatigue Assessments during 2017 were self-declared.

No Fatigue Assessments were conducted during 2017 outage operations.

A search was conducted of PCRS for Grand Gulf (GGN) and Headquarters (HQ) on issues related to the fatigue rule for the assessment period. Six CRs were identified that documented issues associated with fatigue management.

1.

NIOS identified that per EN-OM-123 Section 5.10, the fatigue management annual review is to be completed and documented by January 30 of each year containing information from the prior calendar year. The annual report containing information from the 2016 calendar year was not completed and documented until February 13, 2017. No prior condition report could be found documenting this procedural noncompliance. The condition was corrected.

2.

NIOS identified that the site did not have a designated fatigue management subject matter expert. This issue has been corrected.

3.

NIOS identified that:

A review was conducted of records maintained by the Access Authorization & Fitness for Duty (AA/FFD) department of Fatigue Assessments performed during the assessment period. None of the assessments revealed fatigue as contributing to the reason for the assessment, and no further management actions directly related to the assessments was warranted. A summary of the Fatigue Assessments is provided below.

General No Fatigue Assessments during 2017 were self-declared.

No Fatigue Assessments were conducted during 2017 outage operations.

Print this Report Save to Local PC dellis@entergy.com David Licensing Specialist Ellis Locked Feb 19, 2018 at 12:08:50 PM The Fatigue Management Program at Grand Gulf Nuclear Station is effective.

A review of the program records indicates that through management controls, work hour violations are minimal and are exigent, and fatigue assessments are conducted when events warrant.

Grand Gulf has taken the appropriate action using the Corrective Action Program to identify and correct issues associated with fatigue rule requirements. However, continued management attention is need to ensure that PQS reviews are timely, and that shift schedules continue to be followed to ensure that call-outs for on-shift ERO and Fire Brigade commitments are minimized.