The inspectors identified an
NCV of
10 CFR Part 50, Appendix B, Criterion V, Procedures, because NextEra did not ensure adequate separation was maintained between temporary
scaffolding and safety-related equipment. Specifically, six instances of
scaffolding installed in the plant were identified with less than the minimum standoff distance to safety-related equipment specified in NextEra procedures and no corresponding engineering evaluation to support these deviations. NextEra entered this
NCV into their
CAP as
AR 01933827 and assessed the six deviations for any impact on the associated safety-related systems. This performance deficiency 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, NextEra did not evaluate
scaffolding installations when insufficient separation to safety-related equipment existed after procedural requirements were revised to a more restrictive value. 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
Significance Determination Process for Findings At-Power and determined to be of very low safety significance (Green), because 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 Problem Identification and Resolution, Evaluation, because NextEra personnel did not perform an adequate extent of condition review after revision of their erection of scaffold procedure. This performance deficiency directly contributed to multiple instances of scaffold members erected within two inches of safety-related equipment without an engineering evaluation [P.2].
