An NRC identified non-cited violation (
NCV) of
Technical Specification 6.8.1, was identified which requires that written procedures be established, implemented, and maintained covering activities referenced in NRC
Regulatory Guide 1.33, Revision 2, dated February 1978. The licensees procedures for seismic restraint of ladders: MA-AA- 100-1008, Station Housekeeping and Material Control; QI-13-PSL, Housekeeping and Cleanliness Controls Methods St. Lucie Plant; ADM-04.02, Industrial Safety Program; and ADM-27.11, Scaffold Control, were not implemented as written on ladders that were installed near safety-related equipment. The inspectors identified four examples of ladders not seismically restrained in accordance with the licensees procedures. During the licensees extent of condition review, 24 additional examples of ladders not in compliance with procedure requirements were identified. The licensees repeated failure to comply with procedures to seismically restrain ladders was a performance deficiency. Immediate corrective actions included completing a site-wide walk-down of the safety-related systems to identify and bring into procedural compliance any ladders that were not seismically restrained. The licensee entered this violation into the corrective action program as action request 1829233. The performance deficiency was determined to have more than minor significance because if left uncorrected, the failure to comply with station procedures to ensure adequate restraining of seismically controlled ladders, could
lead to a more significant safety concern. Specifically, seismically unrestrained ladders could impact safety-related equipment during a design basis seismic event. The inspectors evaluated the risk of this finding using Manual Chapter 0609 Appendix A,
Significance Determination Process for Findings At-Power, Exhibit 2-
Mitigating Systems Screening questions. The inspectors determined that the finding was of very low safety significance because it did not require a quantitative assessment as determined in Exhibit 2. The finding involved the cross-cutting area of human performance, in the component of resources and the aspect of complete and accurate procedures (
H.2.c) in that, the licensee failed to ensure complete, accurate, and up-to-date procedures were available for licensee personnel to ensure ladders were restrained to prevent seismic interaction with safety-related systems during a design basis seismic event.
