05000244/FIN-2013004-02
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Finding | |
|---|---|
| Title | Failure to Implement Scaffolding Procedure Requirements |
| Description | The inspectors identified a Green NCV of Title 10 of the Code of Federal Regulations (10 CFR) 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, because CENG personnel did not accomplish activities affecting quality in accordance with documented procedures. Specifically, CENG personnel did not adequately implement scaffolding control procedural requirements to ensure that scaffolding did not block or restrict full operation of surrounding equipment or maintain 1-inch minimum clearances for safety-related equipment, which resulted in 13 deficiencies associated with scaffolding erection in the last year. CENG staff implemented immediate corrective actions by adjusting the scaffolding, removing the scaffolding, and/or evaluating the scaffolding. Additionally, these issues were documented in CENGs corrective action program (CAP). The finding was more than minor because it was associated with the external factors and equipment performance attributes of the Mitigating Systems cornerstone and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, CENG personnel did not follow procedural guidance when erecting scaffolding on 13 occasions during a 1-year period, which resulted in a fire protection suppression system being declared non-functional and the potential to affect other safety-related and fire protection equipment. Additionally, this issue is similar to example 4a described in IMC 0612, Appendix E, Examples of Minor Issues, which states that this type of issue is not minor if a licensee routinely fails on similar issues. The inspectors evaluated the finding using IMC 0609, Attachment 0609.04, Initial Characterization of Findings, issued June 19, 2012. The attachment instructs the inspectors to utilize IMC 0609, Appendix F, Fire Protection Significance Determination Process, issued February 28, 2005, when the finding involves fixed fire protection systems; the most significant scaffolding issue impacted the S14 fixed fire protection system, which was declared non-functional. A low degradation rating was assigned to this finding because the S14 system was determined to be functional after a detailed analysis was performed, and S14 was still expected to display nearly the same level of effectiveness and reliability as it would have had the degradation not been present. Therefore, the inspectors determined the finding was of very low safety significance (Green). The finding has a cross-cutting aspect in the area of Problem Identification and Resolution, Corrective Action Program, because CENG personnel did not thoroughly evaluate problems such that the resolutions addressed causes. Specifically, CENG personnel had multiple opportunities following the inspectors identification of scaffolding issues on October 25, 2012, and prior to August 15 and September 10, 2013, to thoroughly evaluate recent scaffolding problems such that the resolutions addressed causes. |
| Site: | Ginna  |
|---|---|
| Report | IR 05000244/2013004 Section 1R13 |
| Date counted | Sep 30, 2013 (2013Q3) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.13 |
| Inspectors (proximate) | A Rosebrook D Dodson D Schroeder J Laughlin N Perry T Moslak |
| Violation of: | 10 CFR 50 Appendix B Criterion V |
| CCA | P.2, Evaluation |
| INPO aspect | PI.2 |
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Finding - Ginna - IR 05000244/2013004 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Ginna) @ 2013Q3
Self-Identified List (Ginna)
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