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The NRC identified a Green, non-cited violThe NRC identified a Green, non-cited violation of Technical Specification (TS) 6.8.1, Procedures and Programs, for the licensees failure to establish, implement, and maintain written procedures covering activities referenced in NRC Regulatory Guide 1.33, Revision 2, dated February 1978. Specifically, the licensee failed to track, inspect and evaluate the placement of temporarily installed ladders (TILs) that were touching or placed near safety-related Structures, Systems, and Components (SSCs) with the potential to interact with the SSCs during a design basis seismic event. Corrective actions completed included removing TILs that were no longer being used and entering the remaining ladders into the corrective action program (CAP) for tracking and inspection, and reviewing whether any ladder required an engineering evaluation. The licensees repeated failure to track, inspect, or complete an engineering evaluation on TILs located near safety-related SSCs as required by licensee procedures ADM-27-21 and MA-AA-100-1008 was a performance deficiency. The performance deficiency was more than minor because if left uncorrected, the performance deficiency had the potential to lead to a more significant safety concern. Specifically, routinely not tracking, inspecting or completing engineering evaluations of TILs that are touching or located near safety-related SSC could allow ladders to be installed, which interact with safety-related equipment resulting in equipment rendered inoperable during a design basis seismic event. The finding screened as green because the finding did not represent an actual loss of function of at least a single Train for > its TS Allowed Outage Time OR two separate safety systems out-of-service for > its TS Allowed Outage Time. The finding involved the crosscutting area of Problem Identification and Resolution, in the aspect of Identification, in that non-compliances associated with TILs had been long-term issues, which the licensee had failed to identify and enter into the CAP. As a result, the ladder issues remained unnoticed and unaddressed in the CAP until identified by the inspectors (P.1)the CAP until identified by the inspectors (P.1)  
23:59:59, 31 March 2015  +
05000335  +  and 05000389  +
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00:52:43, 21 February 2018  +
23:59:59, 31 March 2015  +
Procedural Non Compliances Relating To Temporarily Installed Ladders Located Near Safetyrelated SSCs  +