05000387/FIN-2015002-04
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Finding | |
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| Title | Multiple Violations of Work Hour Limitations by Licensed Operators |
| Description | The inspectors identified a finding of very low safety significance (Green) and associated NCV of 10 CFR 26.205, Work Hours, because Susquehanna did not ensure that the working hours of licensed operators were maintained within regulatory limits. Specifically, numerous instances of violations were identified in the operations department in which individuals exceeded the required work hour limits while performing duties subject to work hour controls. In review of the issue, the inspectors identified that Susquehanna inappropriately excluded some works hours performing non-covered work from the total accumulated work hours, which allowed individuals to perform covered work while in excess of the work hour limits without meeting the requirements for applying a waiver. Susquehanna entered the issue into the CAP as CR-2015-15708 and initiated action to evaluate the extent of the matter and communicate the issue with the operations department, reinforce the standards for work hour tracking with station personnel, and ensure work hours are appropriately tracked. The inspectors determined that the finding was more than minor because Susquehanna inadequately implemented the requirements of 10 CFR 26.205 and NDAP-QA-0025 routinely. Therefore, if the performance deficiency were left uncorrected, the continued process of not including all hours accumulated toward work hour limits and allowing workers to exceed work hour limits, had the potential to lead to a more significant safety concern. The finding was also similar to IMC 0612, Appendix E, "Examples of Minor Issues," Example 9.a. In accordance with IMC 0609.04, Initial Characterization of Findings, dated June 19, 2012, and Exhibits 1 and 2 of IMC 0609, Appendix A, The SDP for Findings At-Power, dated June 19, 2012, the inspectors determined that this finding is of very low safety significance (Green) because no transients, loss of function of a mitigating system, or mismanagement of reactivity occurred as a result of licensed operators performing covered work while not in compliance with the work hour limits specified in 10 CFR 26.205. This finding has a cross-cutting aspect in the area of Problem Identification and Resolution, Identification, because Susquehanna did not identify the issues completely, accurately, and in a timely manner. Specifically, Susquehanna identified violations of work hour limits on multiple occasions but the CRs were not in sufficient detail to ensure they were appropriately prioritized and assigned for resolution. Individuals did not recognize that work performed doing non-covered work was to be counted as hours accumulated towards the work hour limitations and thus discounted the violations as erroneous. |
| Site: | Susquehanna  |
|---|---|
| Report | IR 05000387/2015002 Section 4OA2 |
| Date counted | Jun 30, 2015 (2015Q2) |
| Type: | NCV: Green |
| cornerstone | Initiating Events, Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71152 |
| Inspectors (proximate) | F Bower H Gray J Greives J Kulp N Graneto T Daun A Turilin B Smith C Graves |
| Violation of: | 10 CFR 26.205 |
| CCA | P.1, Identification |
| INPO aspect | PI.1 |
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Finding - Susquehanna - IR 05000387/2015002 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Susquehanna) @ 2015Q2
Self-Identified List (Susquehanna)
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