ML22047A218
| ML22047A218 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 02/16/2022 |
| From: | Wolf Creek |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation, Office of Nuclear Security and Incident Response |
| References | |
| Download: ML22047A218 (2) | |
Text
NRC FFD Program Performance Data Reporting 10CFR Part 26 - FM Internal Use Only This attachment provides the entire narrative as the NRC form has been created with boxes that scroll down, and when printed, the information prints very small due to the way the NRC has built the electronic Fatigue Management form.
Analysis of Waiver Assessment Data:
Five (5) waivers are annotated for Waiver Issuance and Waiver Distribution as this NRC form only applies to covered workers. The waivers occurred while the plant was on-line. Waivers were issued for five (5) covered workers in maintenance and two (2) non-covered workers one (1) from planning and one (1) from quality control. A total of seven (7) waivers were issued on 07-27-2021. Issuing waivers and performing fatigue assessments supports ensuring all workers exceeding NRC work hour limits are fit for duty. The work effort was in support of a high angle rescue team and the work effort was for a hydrometer replacement. Fatigue Assessment and Waivers were issued appropriately, and procedure guidance was followed. Minor administrative errors were noted on fatigue assessment and waiver form completion.
Procedure change requests were initiated for the Fatigue Assessment and Waiver forms to assist end user in form performance.
Analysis of Fatigue Assessment Data:
Seven (7) fatigue assessments for waivers were performed on 07-27-2021. The plant was on-line, and no performance actions were documented from assessment review. A procedure change request has been initiated for the Fatigue Assessment form to revise some sections of the form to make form a little bit clearer for the end user.
==
Conclusions:==
The site continues to effectively monitor and manage the fatigue rule.
Summary and Status of Corrective Actions:
Topic 1 - For 2021 maintenance incurred three (3) work hour violations for three (3) individuals in November. Maintenance initiated a trend condition report (CR) 100010917 to address this concern.
Actions taken: The manager of maintenance is to provide training on this issue and give clear and specific guidance on regulatory requirement to not violate NRC work hour rules. Due date is 4/28/2022.
(OPEN)
Topic 2 - (Historical) The 2021 NRC fitness for duty inspection exit meeting, the lead inspector indicated he would be documenting in the inspection report a licensee-identified, Green non-cited violation (NCV) of 10 CFR 26.31(c)(3) which requires that as soon as practical after an event involving a human error, where the human error may have caused or contributed to the event, the licensee or other entity shall test the individual(s) who committed the error(s). Contrary to this, QA audit 18-09-FFD/FM identified that Fatigue Assessments were not performed on 4/12/18 and 6/21/18. Licensee-identified NCVs are not assigned cross-cutting aspects. CR 127487 was written for the original issue identified by QA. CR 10001396 was written to track this violation. (CLOSED)
Action taken: In 2018 the post-event section of the For-Cause /Post Event/Fatigue Determination form (APF 01A-001-02) was revised and aligned to 10 CFR 26 requirements. This action provides clear and specific guidance and upon a current review, no additional issues were discovered.
Topic 3 - During RF24, Maintenance scaffold leads were loaned to Engineering Projects to support scaffold activities. Projects leadership had the responsibility for assigning outage schedules and admin codes to apply outage rules and approve timesheets in EmpCenter. It was recognized that 2 Maintenance Support employees that were on-loan to Projects during RF24 were assigned daily schedules at the end of RF24; however, they were left on outage rules. Outage rules are not as conservative as on-line rules and are only to be applied when we are off-line. The appropriate Admin
NRC FFD Program Performance Data Reporting 10CFR Part 26 - FM Internal Use Only Code was applied, and the timesheets were re-approved, which allowed verification that no work hour violations occurred during this time.
Actions taken: CR 10008832 (CLOSED) Event shared with all work hour tracking timekeepers to raise awareness of the importance in task completion and verification for loaned individuals.
General Comments:
The Fatigue Management Program Review did not document any performance gaps or additional issues.
(Reference QH-2022-2296)