A finding of very low safety significance, and an associated
NCV of
Technical Specification (TS) 5.2.2.e, Administrative Controls, Organization, Unit Staff, was identified by the inspectors for the licensees failure to follow the Administrative Control Procedure (
ACP) 101.4, Overtime Limits and Requirements, Section 3.1 (3) requirement for assuring that personnel do not exceed the overtime requirements without prior authorization. The licensee entered this issue into its corrective action program to evaluate the adequacy and effectiveness of the
ACP, and to identify required procedure revisions to prevent recurrence. Using the minor questions in
Appendix B of IMC 0609, the inspectors determined that the finding was more than minor because the issue was associated with the
Initiating Events Cornerstone attribute of Human Performance and affected the cornerstone objective of limiting the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, the unrecognized periods of excessive work hours would increase the likelihood of human errors during refueling outage activities and response to plant events, i.e. fire watches. Since these periods were unrecognized and not authorized in advance by management, the excessive work hours could result in more significant safety concerns. Because this issue occurred during the last refueling outage, the finding was evaluated in accordance with
IMC 0609, Appendix G, Shutdown Operations
SDP. Using Checklist 7, Boiling Water Reactor (
BWR) Refueling Operation with
RCS Level > 23, contained in Attachment 1, the inspectors determined that since the plant had appropriately met the safety function guidelines for core heat removal, inventory control, power availability, containment integrity, and reactivity control, and since a phase 2 or phase 3 analysis was not required, the finding screened as Green using Figure 1. This finding has a cross-cutting aspect in the area of Human Performance for the Resources safety culture component because the licensee did not ensure that sufficient trained personnel and procedures were available and adequate to assure nuclear safety by maintaining work hours within working hour limits. [H.2.(b)
