A self-revealing potentially Greater than Green
AV of
10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, was identified when the licensee failed to identify a crack in a weld located in the Unit 1 High Pressure Injection (
HPI) system. In 2004, a procedure was developed for augmented in-service inspection program ultrasonic examinations which effectively removed reasonable assurance that
HPI nozzle component cracking would be identified and corrected. NDE-995, Ultrasonic Examination of Small Diameter Piping Butt Welds and Base Material for
Thermal Fatigue Damage, did not contain the necessary steps to achieve acceptable coverage for
UT examinations when limitations were encountered. The inspectors determined that the failure to ensure that station procedure NDE-995 was adequate to identify and correct cracking in weld 1-RC-201-105 was a performance deficiency. The inspectors determined that the performance deficiency was more than minor because it affected the Design Control attribute of the
Initiating Events cornerstone and adversely affected the cornerstone objective in that an unidentified crack resulted in
reactor coolant system pressure boundary leakage and a forced shutdown of Unit 1. The finding was determined to require a detailed risk analysis because the condition could have resulted in a leak which exceeded the
reactor coolant system leak rate for a small-break loss of coolant accident. There was no immediate safety concern because the crack was repaired. The inspectors determined this finding has a cross-cutting aspect of
H.7 in the Documentation component of the Human Performance area because the licensee did not create and maintain complete, accurate, and up-to-date documentation in procedure NDE-995 to ensure acceptable coverage for
UT examinations.
