The inspectors identified an
NCV of
10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, because Ginna did not adequately implement
scaffolding control procedural requirements related to post-installation inspections and engineering safety evaluations for
scaffolding constructed within 1 inch of safety-related equipment,. During a plant walkdown on March 18, 2008, the inspectors identified multiple examples where
scaffolding was not installed in accordance with Constellation Energy corporate and site procedures. For example, contrary to step 3.3.8 of Ginna procedure A-1406.1, Requirements for the Installation of
Scaffolding, scaffolds were installed within 1 inch of safety-related equipment and did not receive an engineering safety evaluation. Similar scaffold-related issues have occurred over 26 times since July 2007, as documented in CR 2008-0292. This finding is more than minor because it was associated with the Mitigating System cornerstone attributes of protection against external factors such as a seismic event and equipment performance such as reliability. The finding affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to
initiating events to prevent undesirable consequences. The finding is of very low safety significance, because the finding is not a design or qualification deficiency, did not represent a loss of a safety function, and did not screen as potentially risk significant due to external events. This finding is similar to example 4.a in
Appendix E of IMC 0612, in that Ginna had recurring examples of not performing evaluations for scaffolds constructed within the minimum allowed distance of safety related equipment. The finding has a crosscutting aspect in the area of human performance, in that the Ginna did not effectively communicate expectations regarding work practices to workers constructing
scaffolding or to supervisors who routinely monitor these activities to follow procedural requirements (
H.4.b)