Title
10 CFR 50, Appendix B, Criterion V states, in part, that activities affecting quality shall be prescribed by documented instructions and procedures appropriate to the circumstances and shall be accomplished in accordance with these instructions and procedures. Contrary to the above, on November 5, 2012 and November 7, 2012, the licensee failed to incorporate
ASME Code required
VT-2 examination requirements into work instructions for work to be performed on a safety-related component. Specifically,
WO 1453938-30 and
WO 1453938-36, which required cutting and welding activities to be performed on the
RHRSW system during installation of branched sub-assemblies, did not contain
EC 385181 CC-AA-103, Attachment C. The
EC 385181 CC-AA-103, Attachment C is the document that contained the requirement to perform a
VT-2 examination immediately after sub-assembly installation as required by the
ASME Code Section XI. On November 12, 2012, Project Management initiated
IR 1439104,
VT-2 Inspections Not Performed.
Issue Report 1439104 identified that the required
VT-2 had not been performed on the installed sub-assemblies under
WOs 1453938-30 and 145398-36. This issue is more than minor because the performance deficiency, if left uncorrected, would have the potential to
lead to a more significant safety concern. Specifically, not performing the
VT-2 system pressure/leakage test following hot tapping the
RHRSW line would call into question the quality of
welds created during hot tapping of the
RHRSW line and could potentially undermine the integrity of the
RCS pressure boundary because that
RHRSW line was in operation during the hot tapping process. This finding was determined to be of very low safety significance or Green in accordance with
IMC 0609, Appendix G because at least one
RHR loop (train A) was
operable during the time period from when the hot tapping was performed to when the
ASME Code required
VT-2 was finally performed on the
RHRSW Train B line. In addition, the sub-assemblies
weld locations off the
RHRSW train B line did not exhibit any system leakage during the
VT-2 examination that was conducted on November 12, 2012.
