The inspectors identified an
NCV of
10 CFR 50, Appendix B, Criterion V, Procedures, because
PSEG did not ensure adequate separation was maintained between temporary
scaffolding and safety-related equipment. Specifically, the inspectors identified numerous scaffolds installed in the plant with less than the minimum standoff distance to safety-related equipment specified in
PSEG procedures and no engineering evaluation to support these deviations. Following inspector identification of the issue,
PSEG performed independent walkdowns of all
scaffolding and entered all discrepancies into their
CAP. All discrepancies were corrected and assessed for any potential impact to the operability or functionality of the system and
PSEG determined that there was no loss or degradation of equipment or function specifically designed to mitigate a seismic event.
PSEG also initiated an apparent cause evaluation (
ACE 70152874) on numerous
scaffolding issues identified by the inspectors and
PSEG Nuclear Oversight (NOS) personnel. This
PD was considered more than minor because it affected the protection against external factors attribute of the
mitigating systems cornerstone and its objective to ensure the availability, reliability, and capability of systems that respond to
initiating events to prevent undesirable consequences. Specifically,
PSEG routinely did not evaluate scaffold installations when insufficient separation to safety-related equipment was provided. Additionally, it was similar to example 4.a in
IMC 0612, Appendix E, Examples of Minor Issues, which states that the issue of failing to appropriately evaluate scaffold installation as required by procedures is more than minor if the licensee routinely failed to perform engineering evaluations. The issue was evaluated in accordance with
IMC 0609, Appendix A, The
SDP for Findings At-Power, and determined to be of very low safety significance (Green) since it did not involve the loss or degradation of equipment or function specifically designed to mitigate a seismic event. This finding has a cross-cutting aspect in the area of Human Performance, Work Practices, because
PSEG did not ensure that personnel work practices support human performance. Specifically,
PSEG personnel did not follow scaffold installation procedures when they routinely installed scaffold within the allowable clearance of safety-related equipment without an engineering evaluation.
