ML20043F148
| ML20043F148 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 01/30/2020 |
| From: | Brown L Entergy Nuclear Operations |
| To: | Document Control Desk, Office of Nuclear Security and Incident Response |
| References | |
| Download: ML20043F148 (7) | |
Text
Attachment 5 Page 1 of 7 Annual Review Report - WF3 2019 CY The following provides a typical report content and format template for the annual reviews required by 10 CFR 26.205(e) and 10 CFR 26.211(g) per steps 5.10 [2] and 5.10 [5] of this procedure.
FATIGUE MANAGEMENT PROGRAM ANNUAL EFFECTIVENESS REVIEW Waterford 3 2019CY NOTE 10 CFR 26.205(e) states: At a minimum, this review must address (i) Individuals whose actual hours worked during the review period exceeded an average of 54 hours6.25e-4 days <br />0.015 hours <br />8.928571e-5 weeks <br />2.0547e-5 months <br /> per week in any shift cycle while the individuals work hours are subject to the requirements of § 26.205(d)(3) or in any averaging period of up to 6 weeks, using the same averaging period durations that the licensee uses to control the individuals work hours, while the individuals work hours are subject to the requirements of
§ 26.205(d)(7); (See table below)
(ii) Individuals who were granted more than one waiver during the review period; and (No Waivers granted for 2019 CY)
(iii) Individuals who were assessed for fatigue under § 26.211 during the review period. (See below III)
A. REVIEW OF WAIVERS GRANTED DURING THE ASSESSMENT (0 Waivers granted)
I. Work hours of covered workers were reviewed using the work hour database (PQ&S) that calculates work hours and compares to 10CFR26 limits, and data results taken from PQ&S. Table below summarizes all the covered disciplines for 2019 (January 1
- December 31, 2019) 1 Violation 48 Hr. rule (emergent DEH trouble No Waivers Maintenance - FIN CR-WF3-2019-05109 shooting (Non-outage) FTR #440 Procedure Violation supervisors not -
Maintenance - Mechanical CR-WF3-2020-00408 qualified for PQ&S qualified CR-WF3-2019-04228 CFAM audit - watch bills -
CR-WF3-2019-05573 (Ops) OE GGNS - Fatigue rule compliance plan. -
1 Violation 72 Hr. rule (MSIS A valve during disassembly in progress lift) (Follow up No Waivers CR-WF3-2019-02035 Assessments performed) paper work missing for 3 individuals not sent to Access.
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Attachment 5 Page 2 of 7 Annual Review Report - WF3 2019 CY Procedure Violation supervisors not -
Maintenance - Electrical CR-WF3-2020-00330 Qualified for PQ&S.
Lack of qualified resources for covered -
CR-WF3-2019-02684 work. (Trending)
PQ&S software issues - unable to verify -
CR-WF3-2019-04467 work greater than scheduled.
PQ&S software issues - glitch that looked -
CR-WF3-2019-09149 like a violation but was not a violation.
Trending - referenced back to CR-WF3- -
CR-WF3-2019-09180 09149.
Fatigue assessment performed but not -
CR-WF3-2020-00502 submitted to access ref CR-WF3-2019-2035.
Procedure Violation supervisors not -
Maintenance - I&C CR-WF3-2020-00422 Qualified for PQ&S.
- Outage rules Reviewed various weekly watch bills and used for 60 Chemistry No CRs generated days of RF 22.
interviewed technicians.
No Waivers PQ&S Violation report would not generate -
Operations CR-WF3-2020-00453 due to software issues 1 Violation not having 34 Hrs. off during a 9- No Waivers CR-WF3-2019-07956 day period (4/10 - 4/18) FTR #441 OE GGNS - Fatigue rule compliance plan -
CR-WF3-2019-05573 (Ops CR) 1 Violation RP 5-man rotation entered with No Waivers Radiation Protection CR-WF3-2019-04821 invalid hour codes PQ&S Violation report would not generate -
CR-WF3-2020-00458 due to software issues 1 Violation exceeded 72 Hr. limit (due to No Waivers Security CR-WF3-2019-01918 relief officer not able to log on to RWP) 1 Violation exceeded 34 Hr. limit due to an No Waivers CR-WF3-2019-03915 entry error in PQ&S Procedure Violation unable to run PQ&S -
CR-WF3-2020-00360 year end reports Inattentive Officer comp measure (Post- No Waivers CR-WF3-2019-08236 event assessment)
PQ&S Violation report would not generate -
Projects CR-WF3-2020-00453 (Ops) due to software issues.
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Attachment 5 Page 3 of 7 Annual Review Report - WF3 2019 CY II. No Waivers granted for 2019 CY.
III. Total Capability assessments performed for 2019 CY were 5 of which none identified Fatigue as a contributor:
1 For cause during Outage - [No CR] medical issue - resolved without management actions.
1 Post-event Online - [CR-WF3-2019-08236] inattentive individual - resolved without management actions.
3 Follow-up during Outage - [CR-WF3-2019-02035]- middle of lift could not safely stop work - resolved without management actions.
IV. REVIEW OF WAIVERS GRANTED DURING THE ASSESSMENT PERIOD No Waivers granted for 2019 CY.
NOTE 10 CFR 26.211(g) states: Licensees shall prepare an annual summary for each nuclear power plant site of instances of fatigue assessments that were conducted during the previous calendar year for any individual identified in § 26.4(a) through (c). Each summary must include (1) The conditions under which each fatigue assessment was conducted (i.e., self-declaration, for cause, post-event, follow-up);
(2) A statement of whether or not the individual was working on outage activities at the time of the self-declaration or condition resulting in the fatigue assessment; (3) The category of duties the individual was performing, if the individual was performing the duties described in § 26.4(a)(1) through (a)(5) at the time of the self-declaration or condition resulting in the fatigue assessment; and (4) The management actions, if any, resulting from each fatigue assessment.
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Attachment 5 Page 4 of 7 Annual Review Report - WF3 2019 CY A. REVIEW OF FATIGUE ASSESSMENTS PERFORMED The data indicated that there were 5 covered worker Capability Assessments performed which generated 0 waivers one in Security and the other 4 in Maintenance. One was 2/8/2019 during the refueling outage (RF22) this was for cause found to be inattentive by both Manager and supervisor (not actually performing covered work at the time - due to medical condition -
personal illness (Maintenance). There were no management actions taken as the assessment shows this not to be fatigue.
The other assessment also performed during the outage in Mechanical Maintenance 3 individuals [reference CR-WF3-2019-02035] were for follow-up they were in progress of a lift and for safety reasons could not stop work. However, these 3 assessments were performed but the paperwork was not submitted to Access - [CR-WF3-2020-00502] generated. The final assessment for 2019 was not during an outage, 11/2/2019 and was classified as post-event individual worked in security and was posted at a fire door for comp measures and the NRC resident indicated that the officer appeared inattentive. After the Fatigue assessment was performed, Fatigue was not identified as a contributor to the event. The officer was assigned a minimum 10-hour break prior to resuming duties. [CR-WF3-2019-08236] CR number not noted on assessment. Again, no management actions taken - not identifying fatigue as the contributor.
B. REVIEW OF OTHER ISSUES AS DOCUMENTED IN CONDITION REPORTS Most issues of concern documented in the condition reports generated during 2019 CY have been about our poor software performance (PQ&S). [CR-WF3-2020-00453, CR-WF3-2020-00458, this issue has been a problem for quite a few years however, this has been resolved with new software being introduced for 2020. The vendor, CERTREC has recently released FRMS (Fatigue Rule Management System), a new Fatigue Rule Management System to simplify Fatigue Rule Compliance. A state-of-the-art, web-based platform - no software has to be installed on networks or computers, eliminating maintenance and upkeep tasks. They will be responsible for the uptime and maintenance. Users of 10 CFR 26.205 compliance software have complained about the same things - requires lots of maintenance, takes hours to produce reports and are many times inaccurate. Other concerns written up in CRs with regard to fatigue management are supervisors for covered workers not maintaining their PQ&S Qualifications [CR-WF3-2020-00330, CR-WF3-2020-00408, and CR-WF3-2020-00422] this appears to be more of a new responsibilities issue and CRs documenting violations of the fatigue rule [CR-WF3-2019-05109, CR-WF3-2019-02035, CR-WF3-2019-07956, CR-WF3-2019-04821, CR-WF3-2019-01918, CR-WF3-2019-03915] note that 6 individuals violated the hours over rules, a few of these were invalid hour codes and entry errors.
C. OBSERVATIONS / CONCLUSIONS REQUIRING CORRECTIVE ACTION Our Fatigue Management is effective, just not as effective as it can be. With this 2019 CY individual department effectiveness reviews this is already a better process. Once this form (EN-OM-123 Attachment 10 Fatigue Management Program Periodic EN-OM-123 R15
Attachment 5 Page 6 of 7 Annual Review Report - WF3 2019 CY WAIVER DISTRIBUTION BY TYPE OF LIMIT (A)
WORK HOUR LIMIT OPERATIONS MAINTENANCE SECURITY HP / RADPRO CHEMISTRY FIRE BRIGADE (B)
Max ceilings:
Online Outage Online Outage Online Outage Online Outage Online Outage Online Outage 16h max in 24h 0 0 0 0 0 0 0 0 0 0 0 0 26h max in 48h 0 0 0 0 0 0 0 0 0 0 0 0 72h max in 7d 0 0 0 0 0 0 0 0 0 0 0 0 Rest Breaks:
Online Outage Online Outage Online Outage Online Outage Online Outage Online Outage 10h between work periods 0 0 0 0 0 0 0 0 0 0 0 0 34h in any 9-days 0 0 0 0 0 0 0 0 0 0 0 0 Cumulative Fatigue Limits:
54h Avg - Online or Outage 0 0 0 0 0 0 0 0 0 0 0 0 Minimum Days Off - Outage:
1 MDO / 7 days (rolling) 0 3 MDO / 15 day period 0 0 0 0 4 MDO / 15 day period 0 NUMBER OF WAIVERS PER INDIVIDUAL EMPLOYEE (C)
NUMBER OF WAIVERS OPERATIONS MAINTENANCE SECURITY HP / RADPRO CHEMISTRY FIRE BRIGADE (B) 1 0 0 0 0 0 0 2 0 0 0 0 0 0 3 0 0 0 0 0 0 4 0 0 0 0 0 0 5 0 0 0 0 0 0 6 0 0 0 0 0 0 Highest number of waivers for 0 0 0 0 0 0 an individual employee (A similar form may also be available on the NRC Fatigue Management website.)
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Attachment 5 Page 7 of 7 Annual Review Report - WF3 2019 CY Summary of Corrective Actions (if any) taken or planned based on above data:
None NOTES:
A. Provide the total number of instances when covered work was performed under a waiver. For example, if an individual was granted a waiver for a work period that required exceeding 26h in 48h and less than 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> between work periods, a 1 would be placed in each of the two applicable cells. In other words, one waiver for an individual worker could count as multiple instances of work hour limits waived. Do not record any instances where a waiver was granted but not subsequently used.
B. For individuals performing fire brigade duties and other covered duties, count them only under the fire brigade column. Do not double count these individuals.
C. This table is used to record the number(s) of work hour requirements that have been waived per individual worker (employee) in each category. The number of individuals who receive a waiver for only one work hour requirement in a worker category would be placed in row 1 under that category, and the number of individuals who receive a waiver for two or more work hour requirements in a worker category would be placed in the corresponding numbered row under that category. For example, if three people from Operations each have 2 work hour requirements waived, then a 3 is placed in row 2 of the OPERATIONS column. (Three Operators multiplied by two requirements waived equals a total of 6 work hour requirements waived - when multiplied out, this would equal the total waivers identified in the upper section of the table for that group)
Plant: __________ Data provided by: _____________________________
Name / Dept / Date Outage Dates: Bkr Open ____________ Bkr Closed ____________
(use additional lines / pages, if needed for site outage history during the reporting period)
Data source(s): check all that apply PQ&S PCRS EN-OM-123 Forms Other: ___________
(e.g., Attachment 8)
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