A
SL IV
NCV of
10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, was identified by the inspectors for failure to accomplish activities affecting quality in accordance with instructions and procedures. The inspectors identified three examples associated with
scaffolding deficiencies where procedural requirements were not implemented in accordance with applicant procedure MMTP-102, Erection of Scaffold/Temporary Work Platforms and Ladders.
TVA entered the issue into the corrective action program and, as part of the corrective actions, immediately corrected the
scaffolding to comply with procedural requirements, conducted an apparent cause evaluation and completed appropriate engineering evaluations. The inspectors determined that this finding was more than minor because the finding represented an improper/uncontrolled work practice and represented a deviation that, if left uncorrected, could potentially adversely affect the seismic qualification of a system structure or component (
SSC). The cause of this finding was directly related to the work practices component of the Human Performance cross-cutting area because
TVA and Bechtel did not define and effectively communicate expectations regarding procedural compliance and as a result personnel failed to follow procedures (
H.4.b). (Section E.1.1