05000255/FIN-2012005-02
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Finding | |
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| Title | Failure to Manage Non-Covered Worker Hours |
| Description | A finding of very low safety significance was identified by the inspectors for the programmatic failure to appropriately implement procedure, EN-FAP-OM-006, Working Hour Limits for Non-Covered Workers. Two non-covered supervisors and six individual contributors, performing work or overseeing work on a safety-related component, did not follow the procedural requirements of obtaining supervisor approval prior to exceeding working hour limits, document excess work hours in the payroll system, or initiate a condition report in a timely manner. An extent-of-condition review identified two additional instances of individuals, one contractor and one plant employee, not obtaining prior approval to exceed work hour limits nor completing the appropriate documentation. No violation of regulatory requirements occurred since the performance deficiency involved workers not covered by 10 CFR 26.205 through 26.209, which defines the work hour limitations and exceptions for covered workers. The licensee documented the programmatic weaknesses associated with the use of EN-FAP-OM-006 in their corrective action program. The Working Hour Limits for Non-Covered Workers procedure was revised to clarify when and by whom condition reports should be written when working hour limits are to be exceeded, as well as, who should write the report. The finding was more than minor in accordance with IMC 0612, Appendix B, because if left uncorrected, the programmatic failure to appropriately implement work hour limitations for non-covered workers could lead to more significant safety concerns associated with fatigue potentially impacting the conduct and oversight of work on safety significant components. The performance deficiency also affected the Initiating Events cornerstone attribute of Equipment Performance, adversely impacting the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, the individuals who exceeded the working hour limits for non-covered workers were involved in a forced outage for repair and inspection of a control rod drive mechanism housing (part of the primary coolant system pressure boundary) that had a thru-wall leak which caused an emergent plant shutdown. Management review of this issue per IMC 0609 Appendix M, Significance Determination Process Using Qualitative Criteria, effective April 12, 2012, determined that this finding was of very low safety significance, or Green, since the performance deficiency did not directly contribute to the event. The finding had a cross-cutting aspect in the area of Problem Identification and Resolution, related to the cross-cutting component of Corrective Action Program, in that the licensee thoroughly evaluates problems such that the resolutions address causes and extent of conditions and also includes, for significant problems, conducting effectiveness reviews of corrective actions to ensure that the problems are resolved. In this finding, similar instances of non-covered workers not adhering to the standards for work hour limits and not initiating condition reports as required by EN-FAP-OM-006 were identified in 2011, and the corrective actions for those issues were not sufficient to prevent them from occurring again. |
| Site: | Palisades  |
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| Report | IR 05000255/2012005 Section 4OA2 |
| Date counted | Dec 31, 2012 (2012Q4) |
| Type: | Finding: Green |
| cornerstone | Initiating Events |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71152 |
| Inspectors (proximate) | T Taylor A Scarbeary J Corujo -Sandin J Beavers S Shah M Holmberg J Cassidy S Sheldon J Lennartz J Laughlin D Betancour |
| CCA | P.2, Evaluation |
| INPO aspect | PI.2 |
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Finding - Palisades - IR 05000255/2012005 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Palisades) @ 2012Q4
Self-Identified List (Palisades)
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