The NRC identified a very low safety significance (Green)
NCV of
Technical Specification (TS) 5.4.1 for Exelons failure to adequately implement procedure requirements governing the storage of material in a safety-related structure. Specifically, on April 26, 2016, Exelon technicians stored ladders vertically without them being adequately tied off to prevent the ladders from falling over in accordance with
MA-AA-716-026, Station Housekeeping / Material Condition Program. The inspectors identified that the ladders were stored in the PB Unit 2 reactor building (
RB), such that they could fall over and impact safety-related equipment. The inspectors promptly notified Exelon, the ladders were immediately removed, and the condition was documented under
IR 2661309. This finding was more than minor because it was associated with the protection against external factors attribute of the
Mitigating Systems cornerstone and affected the cornerstone objective to ensure the reliability of systems that respond to
initiating events to prevent undesirable consequences. The inspectors evaluated the finding using
IMC 0609, Attachment 4, Initial Characterization of Findings, and Appendix A, The
SDP for Findings At-Power, Exhibit 2. The inspectors determined this finding to be of very low safety significance (Green) because the degraded condition was not a design deficiency that affected system operability; did not represent an actual loss of function of a system; did not represent an actual loss of function of a single train or two separate trains for greater than its TS allowed outage time; and did not represent an actual loss of function of one or more non-TS trains of equipment designated as high safety significant. The finding was determined to have a cross-cutting aspect in the area of Human Performance, Procedure Adherence, because Exelon technicians did not store ladders in safety-related buildings in accordance with station procedures, such that they could not fall over and damage safety-related equipment.
