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#REDIRECT [[IR 05000321/2016010]]
{{Adams
| number = ML16224A795
| issue date = 08/11/2016
| title = NRC Inspection Report 05000321/2016010, February 22, 2016, June 30, 2016
| author name = Gody A
| author affiliation = NRC/RGN-II/DRS
| addressee name = Vineyard D
| addressee affiliation = Southern Nuclear Operating Co, Inc
| docket = 05000321
| license number = DPR-057
| contact person =
| case reference number = EA-16-136
| document report number = IR 2016010
| document type = Inspection Report, Letter
| page count = 13
}}
See also: [[see also::IR 05000321/2016010]]
 
=Text=
{{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II 245 PEACHTREE CENTER AVENUE NE, SUITE 1200 ATLANTA, GEORGIA  30303-1257
  August 11, 2016
  EA-16-136
 
Mr. David Vineyard
Vice President
 
Southern Nuclear Operating Company, Inc. Edwin I. Hatch Nuclear Plant 11028 Hatch Parkway North
Baxley, GA 31513
 
SUBJECT:  EDWIN I. HATCH NUCLEAR PLANT - NRC INSPECTION REPORT
05000321/2016010
Dear Mr. Vineyard:
 
This refers to an inspection completed on June 30, 2016 by the Nuclear Regulatory Commission concerning activities at Southern Nuclear Company's (SNC) Edwin I. Hatch Nuclear Plant  Unit 1.  The purpose of the inspection was to review the circumstances involving the February
2016 identification of an axial linear flaw in a weld located on a non-isolable portion of the Unit 1
recirculation system feedwater piping.  In this case, the weld flaw was originally identified by SNC in October of 1988, and repaired using welding techniques acceptable at that time.  During
the February 2016 refueling outage, as part of the activities associated with installation of a full- structural weld overlay (FSWOL), your staff discovered that the weld flaw had grown through the entire thickness of the original weld and into the overlay material installed in 1988.  SNC's
review ultimately determined that this condition had existed since at least 2006.  On two
occasions, SNC submitted requests to relax the frequency of required non-destructive
examinations of this weld.  Specifically, the basis of the requests stated that the weld had been modified with a standard weld (i.e., FSWOL), when in fact it had only been modified with a less robust design overlay (leak barrier).  On the
basis on these inaccurate statements, the NRC approved the licensee's requests/proposed alternatives.  Had SNC's submittals correctly
identified the nature of the original weld repair, it is unlikely that the NRC would have approved the reliefs/proposed alternatives without requiring the use of a more robust weld repair
technique.  The NRC notes that the axial weld flaw did not result in any RCS pressure boundary leakage during operation of Unit 1, nor did it result in a significant loss of structural integrity.  Additionally, SNC has repaired the weld using a FSWOL, and initiated corrective actions as
discussed in the enclosed inspection report.
 
Based on the results of this inspection, one NRC-identified Green non-cited violation, and one apparent violation (AV) involving 10 CFR 50.9, "Completeness and Accuracy of Information," were identified.  The AV is being considered for escalated enforcement action in accordance
 
with the NRC's Enforcement Policy.  The curre
nt Enforcement Policy is included on the NRC's Web site at http://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html.
D. Vineyard 2
The AV involves two examples in which SNC failed to provide information to the NRC that was
complete and accurate in all material respects.  Specifically, the first example occurred on October 17, 1995, as part of the 3
rd 10-Year Interval Inservice Inspection Program submittal, SNC requested relief from American Society of Mechanical Engineers (ASME) Code requirements (as clarified in NUREG-0313 Rev. 2 and GL 88-01).  The basis for this request
was that weld overlay 1B31-1RC-12BR-E-5 was of standard overlay design (e.g., FSWOL),
when in fact, the overlay was a "design" overlay (leak barrier).  The second example occurred on May 30, 2000 when SNC submitted a letter, "Edwin I. Hatch Nuclear Plant - Unit 1, Reactor
Coolant System (RCS) Weld Overlay Examinations."  In this letter, SNC requested to defer the required ultrasonic testing exam for the 1B31-1RC-12BR-E-5 weld overlay, again based in part that it was an FSWOL when in fact, the overlay was a less robust design overlay.
 
These submittals were material to the NRC because they were used by the NRC to approve the
reliefs/proposed alternatives.  The basis for the NRC's approval was the statement by the licensee that an FSWOL had been installed.  Had SNC's submittals correctly identified the weld overlay as a design overlay, it is unlikely that the NRC would have approved the
reliefs/proposed alternatives.
 
The circumstances surrounding this AV, your corrective actions, the significance of the issue, and the need for lasting and effective corrective action were previously discussed between members of your staff and the NRC.  As a result, it may not be necessary to conduct a pre-
decisional enforcement conference in order to enable the NRC to make an enforcement
decision. In addition, because your facility has not been the subject of escalated enforcement
within the past two years, and based on our current understanding of your corrective actions, a
civil penalty may not be warranted in accordance with Section 2.3.4 of the Enforcement Policy.  The final decision will be based on you confirming on the license docket that the corrective actions previously described or discussed wi
th the NRC staff have been or are being taken.
Before the NRC makes its enforcement decision, we are providing you an opportunity to (1) respond in writing to the AV in this inspection report within 30 days of the date of this letter, or (2) request a Pre-decisional Enforcement Conf
erence (PEC).  If a PEC is held, the NRC will issue a press release to announce the time and date of the conference, and the conference will
be open to public observation.  If you decide to participate in a PEC, please contact Shakur
Walker at 404-997-4639 within 10 days of the date of this letter.  A PEC should be held within
30 days of the date of this letter. 
 
If you choose to provide a written response, it should be clearly marked as a "Response to
Apparent Violations
in NRC Inspection Report 05000321/2016010, EA-16-136" and should include (1) the reason for the AVs or, if contested, the basis for disputing the apparent violation;
(2) the corrective steps that have been taken and the results achieved; (3) the corrective steps
that will be taken; and (4) the date when full compliance will be achieved.  Your response may reference or include previously docketed correspondence, if the correspondence adequately addresses the required response.  Additionally, your response should be sent to the NRC's
Document Control Center, with a copy mailed to Anthony Gody, Director of Reactor Safety,
Region II, 245 Peachtree Center Avenue NE, Atlanta, GA  30303, within 30 days of the date of
this letter.  If an adequate response is not received within the time specified or an extension of
time has not been granted by the NRC, the NRC will proceed with its enforcement decision or schedule a PEC. 
D. Vineyard 3
If you choose to request a PEC, the conference will afford you the opportunity to provide your perspective on these matters and any other information that you believe the NRC should take
into consideration before making an enforcement decision.  The decision to hold a PEC does not mean that the NRC has determined that a violation has occurred or that enforcement action will be taken.  This conference would be conducted to obtain information to assist the NRC in
making an enforcement decision.  The topics discussed during the conference may include
information to determine whether a violation occurred, information to determine the significance
of a violation, information related to the identification of a violation, and information related to
any corrective actions taken or planned.   
In addition, please be advised that the number and characterization of apparent violation
 
described in the enclosed inspection report may change as a result of further NRC review.  You will be advised by separate correspondence of the results of our deliberations on this matter.
 
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice and Procedure," a copy of this letter, its enclosures, and your response, if you choose to provide one, will be made
 
available electronically for public inspection in the NRC Public Document Room or from the NRC's Agencywide Documents Access and Management
System (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html.  To the extent possible, your response should not include any personal privacy, pr
oprietary, or safeguards information so that it can be made available to the Public without redaction.
 
For administrative purposes, this letter is issued as Inspection Report 05000321/2016010 and the apparent violation is designated as AV 05000321/2016010-01, Failure to Provide Complete
and Accurate Information. 
 
If you have any questions concerning this matter, please contact Mr. Shakur Walker of my staff
at 404-997-4639. 
Sincerely, 
      /RA/  Anthony T. Gody, Director
Division of Reactor Safety 
Docket No. 50-321 License No. DPR-57
 
Enclosure: 
Edwin I. Hatch Nuclear Plant - NRC Inspection
 
  Report 05000321/2016010  w/Attachment:  Supplementary Information 
 
_________________________  SUNSI REVIEW COMPLETE  FORM 665 ATTACHED OFFICE RII:DRS RII:DRS RII:DRP RII:EICS RII:OFC RII:DRS  SIGNATURE *BCC2 SAW4 SRS5 DLG2 SAP1 ATG
NAME BCOLLINS SWALKER SSANDAL DGAMBERONI SPRICE AGODY  DATE 8/2/20166 8/8/2016 8/8/2016 8/9/2016 8/9/2016 8/11/2016 8/    /2016 E-MAIL COPY?    YES NO      YES NO        YES NO      YES NO      YES NO      YES NO     
Letter to Mr. David R. Vineyard from Anthony T. Gody dated August 11, 2016
SUBJECT: EDWIN I. HATCH NUCLEAR PLANT - NRC INSPECTION REPORT
05000321/2016010
DISTRIBUTION
: V. McCree, OEDO  Region II Regional Coordinator, OEDO 
W. Dean, NRR  C. Scott, OGC  M. Johnson, OEDO 
E. Julian, SECY 
D. Decker, OCA 
All Regions Enforcement Coordinators  H. Harrington, OPA 
K. Fowler, OI 
 
H. Bell, OIG 
L. Casey, NRR 
 
D. Strauss, OGC G. Gulla, OE 
L. Wert, RII 
 
M. Franke, RII 
 
B. Collins, RII
 
S. Sandal, RII
C. Rapp, RII A. Gody, RII 
R. Hannah, RII 
J. Ledford, RII 
J. Pelchat, RII 
 
S. Price, RII  D. Gamberoni, RII 
L. Gibson, RII 
OEMAIL Resource 
 
RidsNrrDirs Resource
 
Public
  Enclosure U.S. NUCLEAR REGULATORY COMMISSION
REGION II
 
Docket No.:  05000321
 
License No.:  DPR-57
 
Report No.:  05000321/2016010
 
Licensee:  Southern Nuclear Operating Company, Inc.
Facility:  Edwin I. Hatch Nuclear Plant, Unit 1
 
  Location:  Baxley, GA 31513
 
Dates:    February 22 - June 30, 2016
 
  Inspectors:  B. Collins, Reactor Inspector
 
Approved by:  Shakur A. Walker, Chief Engineering Branch 3
Division of Reactor Safety
  SUMMARY  IR 05000321/2016010; February 22, 2016 through June 30, 2016; Edwin I. Hatch Nuclear Plant, Unit 1; In-Service Inspection Report.
This report covered a follow-up inspection of unresolved item 05000321/2016001-01 by one
regional inspector.  One NRC-identified non-cited violation (NCV); and one apparent violation
(AV) which is being considered for escalated enforcement action in accordance with the NRC Enforcement Policy, are documented in this report.  The significance of inspection findings are indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red) and determined using Inspection Manual Chapter (IMC) 0609, "Significance Determination Process" (SDP)
dated June 19, 2012.  The cross-cutting aspects are determined using IMC 0310, "Aspects
within the Cross-Cutting Areas," dated December 4, 2014.  All violations of NRC requirements
 
are dispositioned in accordance with the NRC's
Enforcement Policy dated August 1, 2016.  The NRC's program for overseeing the safe operations of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Rev. 5.
 
NRC-Identified and Self-Revealing Findings
Cornerstone: Initiating Events
* AV: The NRC identified an AV of 10 CFR 50.9, "Completeness and Accuracy of Information," for the licensee's failure to provide data to the NRC that was accurate in all material aspects.  Specifically, on two occasions (October 1995, May 2000), the licensee
stated that weld 1B31-1RC-12BR-E-5 had been modified with a full-structural weld overlay
(FSWOL), when in fact it had only been modified with a less robust design overlay (leak
barrier).  The NRC approved the licensee's reques
ts/proposed alternatives in part based on the inaccurate characterization of the welds.  The licensee has since installed the FSWOL and entered the issue into the corrective action program as CR 10197850.
The NRC is considering escalated enforcement on the basis that had the licensee provided
accurate information, it would likely have caused the NRC to reconsider a regulatory position.  (Section 1R08)
* Green: The inspectors identified a Green NCV of 10 CFR 50, Appendix B, Criterion XVI, "Corrective Actions," for the licensee's failure to promptly identify a condition adverse to quality regarding a through-wall flaw in the safe end-to-nozzle weld of the reactor coolant
system N2E nozzle.  The licensee has since repaired the flaw, completed all required post-
repair examinations, and entered this issue entered this into their corrective action program
as CR 10247856.
The performance deficiency was more than minor because it was associated with the
Equipment Performance attribute of the Initiating Events cornerstone and adversely affected the cornerstone objective of limiting the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations.  The inspectors screened this finding using IMC 0609, Appendix A, "The Significance Determination Process (SDP) For Findings At-Power", dated June 19, 2012.  Because after
a reasonable assessment of degradation, the finding could neither result in exceeding the
RCS leak rate for a small LOCA, nor likely affected other systems used to mitigate a LOCA
resulting in a total loss of their function, the finding screened as Green.  This finding has a cross-cutting aspect of Challenge the Unknown in the area of Human Performance (H.11) 
3  because upon discovery of a less robust configuration of the N2E nozzle overlay, the licensee failed to consider the implications on the flaw that had existed in that component since 1988.  (Section 1R08)
  REPORT DETAILS
1. REACTOR SAFETY
Cornerstones: Initiating Events, Barrier Integrity, and Mitigating Systems
1R08 Inservice Inspection Activities (71111.08)
.1 URI 05000321/2016001-01, Reactor Coolant System N2E Weld Flaw
a. Inspection Scope
In Inspection Report 05000321/2016001, the inspectors identified an unresolved item
(URI) associated with a flaw in the 1B31-1RC-12BR-E-5 ("N2E") safe end-to-nozzle weld of the reactor coolant system (RCS).
In July 2015, the licensee submitted a proposed alternative to the American Society of
Mechanical Engineers (ASME) Code, HNP-ISI-ALT-15-01 (ADAMS Accession Number
ML15183A354), to install a full-structural weld overlay (FSWOL) on the N2E nozzle. 
This proposed alternative was approved by the NRC in December 2015 (ADAMS Accession Number ML15349A973). The licensee implemented this proposed alternative during the February 2016 refueling outage (1R27). After removing all but 1/16" of the
existing overlay, the licensee performed a liquid penetrant examination and noted a pair
of linear indications.  Subsequently, the licensee determined that these indications were
actually a single indication, and that it exceeded allowable size limitations according to ASME Code.  Upon further review, the licensee realized that these indications were potentially the result of growth of an inner-diameter, surface-connected intergranular
stress corrosion cracking (IGSCC) flaw found in 1988.  On April 14, 2016, the licensee
 
submitted Licensee Event Report (LER) 05000321/2016-003, "Reactor Coolant System Piping Has Unacceptable Weld Indication Discovered During Refueling Outage," as a result of the discovery, due to a principal safety barrier being seriously degraded.  The licensee has repaired the flaw, installed the full-structural weld overlay, and completed
all required post-installation examinations.  The URI was opened to allow the inspectors
to determine whether the licensee performed all required examinations of the N2E
nozzle between 1988 and 2016, and whether the flaw exceeded minimum wall
limitations at some point during prior operation.
The inspectors identified one apparent violation (AV) with two examples, and one non-
associated Green NCV.  Both are described below in 1R08.b.  Accordingly, URI
05000321/2016001-01 and LER 05000321/2016-003 have been closed.
b. Findings
(i) Inaccurate Information Provided Regarding N2E Nozzle Weld Overlay
Introduction: The NRC identified an AV of 10 CFR 50.9, "Completeness and Accuracy of Information," for the licensee's failure to provide data to the NRC that was accurate in all material aspects.  Specifically, on two occasions (October 1995, May 2000), the licensee stated that the N2E nozzle weld had been modified with a FSWOL, when in fact it had
only been modified with a less robust design overlay (leak barrier).  The NRC has not
made an enforcement decision for this AV.
5  Description: In October 1988, during refueling outage 1R11, the licensee performed an ultrasonic examination (UT) on the N2E nozzle weld and identified an indication in the weld.  The licensee evaluated the indication and determined that it was unacceptable by ASME Section XI criteria.  In November 1988 (still 1R11 outage), the licensee installed a
"design" weld overlay (leak barrier) consistent with paragraph 4.4.2 of NUREG-0313
Revision 2, "Technical Report on Material Selection and Processing Guidelines for BWR
Coolant Pressure Boundary Piping," (ADAMS Accession Number ML031470422).
At the time, the acceptable inspection methodology was delineated in GL 88-01, "NRC Position on IGSCC in BWR Austenitic Stainless Steel Piping," (ADAMS Accession
Number ML031430193).  The licensee appropriately classified the N2E weld as a
Category E weld according to this guidance, and as such, the weld was to be inspected
the following refueling outage and then every other refueling outage thereafter.  The licensee completed the required examinations in 1R12 (March 1990), 1R13 (October 1991) and 1R15 (October 1994) and noted no appreciable change in flaw geometry
 
through these three exams.
On October 17, 1995, the licensee submitt
ed their 3rd 10-year Interval Inservice Inspection (ISI) Program to the NRC.  In that
letter, the licensee detailed their plan to revise the frequency of the N2E examinations from every-other-outage to once-per-10-
years, and stated that one of the bases for this decision was that the overlay was a
"standard" overlay.  This information was not accurate, in that the overlay was, in fact, a
less robust "design" overlay.  In September 1997, on the basis of the information
submitted, the NRC approved
the licensee's proposed plan.
On June 17, 1999, the NRC sent a letter to the Boiling Water Reactor Vessel and
Internals Program (BWRVIP) Chairman which stated that several plants, including Hatch
Unit 1, were scheduled for fall 1999 outages, and that deferral of the required exams
would be acceptable provided certain criteria were met.  One of the criteria was that "The overlay for which deferral is applied meets GL 88-01 or ASME Code Case N-504 (full structural overlay) as opposed to a temporary duty (leakage barrier) overlay."
On May 30, 2000, the licensee submitted a letter to the NRC requesting deferral of the
N2E exam on the basis of the NRC's June 1999 letter.  In this letter, the licensee stated
that "[The N2E weld overlay was] designed and applied as full structural weld overlay."  This information was not accurate, in that the overlay was, in fact, a "design" overlay.  In October 2000, on the basis of the information submitted, the NRC approved this
approach for one refueling cycle (1R19 to 1R20).
Analysis: The licensee's failure to provide information required by the Commission's regulations, orders and license conditions that was complete and accurate in all material
aspects was a violation of NRC requirements.  The NRC determined that this violation
was not associated with a common performance deficiency. 
 
The ROP's significance determination process does not specifically consider the regulatory process impact in its assessment of licensee performance.  Because the regulatory process was affected, it is necessary to address this violation which impeded
the NRC's ability to regulate using traditional enforcement.  Using the examples provided
in Section 6.9.c.1 of the NRC Enforcement Policy, the NRC is considering escalated
enforcement on the basis that had the licensee provided accurate information, it would
 
likely have caused the NRC to reconsider a
regulatory position.  Specifically, the licensee submitted information to the NRC stating that the N2E nozzle weld overlay was a "standard" overlay, when in fact, it was a less robust "design" overlay.  Traditional
enforcement violations are not assessed for cross-cutting aspects.
6  Enforcement: Title 10 CFR 50.9, "Completeness and Accuracy of Information," states, in part, that information required by the Commission's regulations, orders, and license conditions shall be complete and accurate in all material aspects.  Contrary to the above, on two occasions (October 17, 1995 and May 30, 2000), the licensee failed to provide
information that was complete and accurate in all material aspects.  Specifically, the
licensee stated that the N2E nozzle weld overlay was a "standard" overlay, when in fact,
it was a less robust "design" overlay.  These submittals were material to the NRC in that
 
they were instrumental in the NRC's
approval of the licensee's requests for
relief/proposed alternative.  Had the correct information been provided, it would have likely caused the NRC to reconsider its regulatory position.  Compliance was restored in
March 2016 when the licensee installed the "standard" (FSWOL) overlay.
No enforcement is being issued at this time because the NRC has not made a final enforcement decision.  The licensee entered this issue into their corrective action program (CAP) as CR 10197850.  This violation is being treated as an AV pending a
final enforcement determination.  (AV 05000321/2016010-01, "Inaccurate Information
Provided Regarding N2E Nozzle Weld Overlay")
(ii) Failure to Identify N2E Nozzle Weld Through-Wall Flaw
Introduction: The inspectors identified a Green NCV of 10 CFR 50 Appendix B Criterion XVI, "Corrective Actions," for the licensee's failure to promptly identify a condition
adverse to quality regarding a through-wall flaw in safe end-to-nozzle weld of the RCS
N2E nozzle.
Description: On April 21, 2015, the licensee was preparing for the upcoming refueling outage and noted that the N2E weld overlay configuration did not match others of similar
original construction.  Specifically, the N2E weld was thought to be a "standard" overlay
(FSWOL); however, was discovered to be a less robust "design" overlay (leak barrier).  The licensee entered the issue into the CAP as CR 10058892 and decided that in order to obtain full coverage for the non-destructive examination in accordance with ASME
Section XI requirements (for the 4
th 10-year ISI interval), they needed to install a FSWOL.  The licensee planned this activity for the upcoming 1R27 outage (February
2016).  On July 2, 2015, the licensee submitted a letter to the NRC (ML15224B464)
requesting approval for the proposed alternative (FWSOL), and on December 18, 2015, the NRC issued the approval SER (ML15349A973).
In February 2016, when installing the new FSWOL, the licensee identified two small,
axial, linear indications - each of which
was unacceptable by ASME criteria.  In the follow-on corrective actions, the licensee determined that: (1) these two flaws were actually one flaw, (2) it was the same flaw that had been previously identified in October 1988, and (3) it had since grown through the entire thickness of the original weld and
 
into the overlay material (through-wall).
 
Upon review of the licensee's corrective actions in CR 10058892, the inspectors identified that the licensee had only focused on addressing the non-destructive examination requirements associated with the 10-year ISI interval, and no consideration was given to the fact that the actual configuration was less robust than originally thought. 
Thus, the licensee also failed to consider the current condition of the flaw that existed in
 
the N2E safe end-to-nozzle weld since October 1988.
As part of their investigation, the licensee sent the UT examination data from the previous exam (1R22, February 2006) to EPRI for further analysis.  EPRI determined
that although the licensee's exam was adequate in all respects using 2006 technology 
7  and requirements, with EPRI's updated technology and experience, the data suggested that the crack had already grown into the overlay material at that time.
Analysis: The failure of the licensee to promptly identify a nonconformance (through-wall
flaw in ASME Class 1 RCS piping) was a performance deficiency.  The performance
deficiency was more than minor because it was associated with the Equipment
Performance attribute of the Initiating Events cornerstone and adversely affected the
cornerstone objective of limiting the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations.  The inspectors screened this finding using IMC 0609, Appendix A, "The Significance
Determination Process (SDP) For Findings At-Power," dated June 19, 2012.  Because
the finding involved the potential for a Loss of Coolant Accident (LOCA), further
evaluation using Exhibit 1, "Initiating Events Screening Questions" was required.  Because after a reasonable assessment of degradation, the finding could neither result in exceeding the RCS leak rate for a small LOCA, nor likely affected other systems used to mitigate a LOCA resulting in a total loss of their function, the finding screened as
Green.  This finding has a cross-cutting aspect of Challenge the Unknown in the area of
Human Performance (H.11) because upon discovery of a less robust configuration of the N2E nozzle overlay in April 2015, the licensee failed to consider the implications on the flaw that had existed in that component since 1988.
 
Enforcement: Title 10 CFR 50 Appendix B Criterion XVI, "Corrective Actions," states, in part, that "Measures shall be established to assure that conditions adverse to quality,
such as failure, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected."  Contrary to the above, on April 21, 2015, the licensee failed to promptly identify a nonconformance associated with
an ASME Class 1 component (through-wall flaw in the N2E nozzle weld, which
exceeded ASME Section XI limits, as required by 10 CFR 50.55a).  The potential safety
consequence of operating at full power with this type of ASME nonconformance is a challenge to the integrity of the reactor coolant pressure boundary, which increases the likelihood of a LOCA.  Upon discovery of the flaw condition in February 2016, the
licensee entered the condition into their CAP as CR 10058892 and installed the
appropriate FSWOL, which restored compliance.  The licensee has entered this issue into their CAP as CR 10247856.  This violation is being treated as an NCV consistent
with Section 2.3.2 of the Enforcement Policy.  (NCV 05000321/2016010-02, "Failure to
Identify N2E Nozzle Weld Through-Wall Flaw")
4. OTHER ACTIVITIES
4OA6 Meetings
On July 14, 2016, the inspectors presented the inspection results to Mr. James Collins,
Site Licensing, of your staff.  The inspectors confirmed that all proprietary information reviewed during the inspection was returned and that none of the potential report input
discussed was considered proprietary.
ATTACHMENT:  SUPPLEMENTARY INFORMATION
  Attachment KEY POINTS OF CONTACT
Licensee J. Collins, Site Licensing Manager
A. Gordon, Site ISI Program Engineer
 
NRC B. Collins, Reactor Inspector D. Hardage, Senior Resident Inspector
D. Retterer, Resident Inspector
 
LIST OF ITEMS OPENED, CLOSED, DISCUSSED AND UPDATED
Opened 05000321/2016010-01 AV Inaccurate Information Provided Regarding N2E Nozzle
    Weld Overlay
 
Closed 05000321/2016001-01 URI Reactor Coolant System N2E Weld Flaw
 
05000321/2016003  LER Reactor Coolant System Piping Has Unacceptable Weld      Indication Discovered During Refueling Outage
 
Opened and Closed 05000321/2016010-02 NCV Failure to Identify N2E Nozzle Weld Through-Wall Flaw
 
LIST OF DOCUMENTS REVIEWED
Corrective Action Documents 263280, Apparent Cause Determination: Failure to Adequately Monitor and Repair a Defect in 
  1B31-1RC-12BR-E-5, dated 3/25/16
CR10058892: 1B31 Safe End Nozzle Welds, dated 4/21/15 CR10197850: Incorrect Information Submitted to NRC, dated 3/16/16 CR10247856: Violation of 10 CFR 50 Appendix B Criterion XVI, dated 7/13/16
Work Orders/Work Requests: SNC685755, Work Order: Install Full-Structural Weld Overlay on N2E Nozzle (1B31-1RC-12BR-
 
  E-5), dated 7/17/2015
Miscellaneous Documents: HL-5045, Letter from J. T. Beckham, Jr. to Nuclear Regulatory Commission, "Edwin I. Hatch 
  Nuclear Plant, Third 10-Year Interval Inservice Inspection Program," dated October 17, 1995
HL-5952, Letter from H.L. Sumner, Jr. to Nuclear Regulatory Commission, "Edwin I. Hatch    Nuclear Plant, Third 10-year Interval Inservice Inspection Program, Adoption of BWRVIP-75,"    dated June 23, 2000
NL-15-1146, Letter from C.R. Pierce to Nuclear Regulatory Commission, "Edwin I. Hatch 
  Nuclear Plant - Unit 1, Proposed Alternative in Accordance with 10 CFR 50.55a (z)(1) 
  Application of Dissimilar Weld Full-Structural Weld Overlays," dated July 2, 2015 NL-16-0421, Letter from C.R. Pierce to Nuclear Regulatory Commission, "Edwin I. Hatch    Nuclear Plant - Unit 1, Full Structural Weld Overlays on Reactor Recirculation and Residual 
  Heat Removal Systems, Nondestructive Examination Results - Spring 2016 Outage (1R27)," 
 
  dated March 17, 2016
NL-5940, Letter from H.L. Sumner, Jr. to Nuclear Regulatory Commission, "Edwin I. Hatch 
 
  Nuclear Plant - Unit 1, Reactor Coolant System (RCS) Weld Overlay Examinations," dated    May 30, 2000
}}

Revision as of 00:34, 20 June 2019

NRC Inspection Report 05000321/2016010, February 22, 2016, June 30, 2016
ML16224A795
Person / Time
Site: Hatch Southern Nuclear icon.png
Issue date: 08/11/2016
From: Gody A
Division of Reactor Safety II
To: Vineyard D
Southern Nuclear Operating Co
References
EA-16-136 IR 2016010
Download: ML16224A795 (13)


See also: IR 05000321/2016010

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION

REGION II 245 PEACHTREE CENTER AVENUE NE, SUITE 1200 ATLANTA, GEORGIA 30303-1257

August 11, 2016

EA-16-136

Mr. David Vineyard

Vice President

Southern Nuclear Operating Company, Inc. Edwin I. Hatch Nuclear Plant 11028 Hatch Parkway North

Baxley, GA 31513

SUBJECT: EDWIN I. HATCH NUCLEAR PLANT - NRC INSPECTION REPORT

05000321/2016010

Dear Mr. Vineyard:

This refers to an inspection completed on June 30, 2016 by the Nuclear Regulatory Commission concerning activities at Southern Nuclear Company's (SNC) Edwin I. Hatch Nuclear Plant Unit 1. The purpose of the inspection was to review the circumstances involving the February

2016 identification of an axial linear flaw in a weld located on a non-isolable portion of the Unit 1

recirculation system feedwater piping. In this case, the weld flaw was originally identified by SNC in October of 1988, and repaired using welding techniques acceptable at that time. During

the February 2016 refueling outage, as part of the activities associated with installation of a full- structural weld overlay (FSWOL), your staff discovered that the weld flaw had grown through the entire thickness of the original weld and into the overlay material installed in 1988. SNC's

review ultimately determined that this condition had existed since at least 2006. On two

occasions, SNC submitted requests to relax the frequency of required non-destructive

examinations of this weld. Specifically, the basis of the requests stated that the weld had been modified with a standard weld (i.e., FSWOL), when in fact it had only been modified with a less robust design overlay (leak barrier). On the

basis on these inaccurate statements, the NRC approved the licensee's requests/proposed alternatives. Had SNC's submittals correctly

identified the nature of the original weld repair, it is unlikely that the NRC would have approved the reliefs/proposed alternatives without requiring the use of a more robust weld repair

technique. The NRC notes that the axial weld flaw did not result in any RCS pressure boundary leakage during operation of Unit 1, nor did it result in a significant loss of structural integrity. Additionally, SNC has repaired the weld using a FSWOL, and initiated corrective actions as

discussed in the enclosed inspection report.

Based on the results of this inspection, one NRC-identified Green non-cited violation, and one apparent violation (AV) involving 10 CFR 50.9, "Completeness and Accuracy of Information," were identified. The AV is being considered for escalated enforcement action in accordance

with the NRC's Enforcement Policy. The curre

nt Enforcement Policy is included on the NRC's Web site at http://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html.

D. Vineyard 2

The AV involves two examples in which SNC failed to provide information to the NRC that was

complete and accurate in all material respects. Specifically, the first example occurred on October 17, 1995, as part of the 3

rd 10-Year Interval Inservice Inspection Program submittal, SNC requested relief from American Society of Mechanical Engineers (ASME) Code requirements (as clarified in NUREG-0313 Rev. 2 and GL 88-01). The basis for this request

was that weld overlay 1B31-1RC-12BR-E-5 was of standard overlay design (e.g., FSWOL),

when in fact, the overlay was a "design" overlay (leak barrier). The second example occurred on May 30, 2000 when SNC submitted a letter, "Edwin I. Hatch Nuclear Plant - Unit 1, Reactor

Coolant System (RCS) Weld Overlay Examinations." In this letter, SNC requested to defer the required ultrasonic testing exam for the 1B31-1RC-12BR-E-5 weld overlay, again based in part that it was an FSWOL when in fact, the overlay was a less robust design overlay.

These submittals were material to the NRC because they were used by the NRC to approve the

reliefs/proposed alternatives. The basis for the NRC's approval was the statement by the licensee that an FSWOL had been installed. Had SNC's submittals correctly identified the weld overlay as a design overlay, it is unlikely that the NRC would have approved the

reliefs/proposed alternatives.

The circumstances surrounding this AV, your corrective actions, the significance of the issue, and the need for lasting and effective corrective action were previously discussed between members of your staff and the NRC. As a result, it may not be necessary to conduct a pre-

decisional enforcement conference in order to enable the NRC to make an enforcement

decision. In addition, because your facility has not been the subject of escalated enforcement

within the past two years, and based on our current understanding of your corrective actions, a

civil penalty may not be warranted in accordance with Section 2.3.4 of the Enforcement Policy. The final decision will be based on you confirming on the license docket that the corrective actions previously described or discussed wi

th the NRC staff have been or are being taken.

Before the NRC makes its enforcement decision, we are providing you an opportunity to (1) respond in writing to the AV in this inspection report within 30 days of the date of this letter, or (2) request a Pre-decisional Enforcement Conf

erence (PEC). If a PEC is held, the NRC will issue a press release to announce the time and date of the conference, and the conference will

be open to public observation. If you decide to participate in a PEC, please contact Shakur

Walker at 404-997-4639 within 10 days of the date of this letter. A PEC should be held within

30 days of the date of this letter.

If you choose to provide a written response, it should be clearly marked as a "Response to

Apparent Violations

in NRC Inspection Report 05000321/2016010, EA-16-136" and should include (1) the reason for the AVs or, if contested, the basis for disputing the apparent violation;

(2) the corrective steps that have been taken and the results achieved; (3) the corrective steps

that will be taken; and (4) the date when full compliance will be achieved. Your response may reference or include previously docketed correspondence, if the correspondence adequately addresses the required response. Additionally, your response should be sent to the NRC's

Document Control Center, with a copy mailed to Anthony Gody, Director of Reactor Safety,

Region II, 245 Peachtree Center Avenue NE, Atlanta, GA 30303, within 30 days of the date of

this letter. If an adequate response is not received within the time specified or an extension of

time has not been granted by the NRC, the NRC will proceed with its enforcement decision or schedule a PEC.

D. Vineyard 3

If you choose to request a PEC, the conference will afford you the opportunity to provide your perspective on these matters and any other information that you believe the NRC should take

into consideration before making an enforcement decision. The decision to hold a PEC does not mean that the NRC has determined that a violation has occurred or that enforcement action will be taken. This conference would be conducted to obtain information to assist the NRC in

making an enforcement decision. The topics discussed during the conference may include

information to determine whether a violation occurred, information to determine the significance

of a violation, information related to the identification of a violation, and information related to

any corrective actions taken or planned.

In addition, please be advised that the number and characterization of apparent violation

described in the enclosed inspection report may change as a result of further NRC review. You will be advised by separate correspondence of the results of our deliberations on this matter.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice and Procedure," a copy of this letter, its enclosures, and your response, if you choose to provide one, will be made

available electronically for public inspection in the NRC Public Document Room or from the NRC's Agencywide Documents Access and Management

System (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response should not include any personal privacy, pr

oprietary, or safeguards information so that it can be made available to the Public without redaction.

For administrative purposes, this letter is issued as Inspection Report 05000321/2016010 and the apparent violation is designated as AV 05000321/2016010-01, Failure to Provide Complete

and Accurate Information.

If you have any questions concerning this matter, please contact Mr. Shakur Walker of my staff

at 404-997-4639.

Sincerely,

/RA/ Anthony T. Gody, Director

Division of Reactor Safety

Docket No. 50-321 License No. DPR-57

Enclosure:

Edwin I. Hatch Nuclear Plant - NRC Inspection

Report 05000321/2016010 w/Attachment: Supplementary Information

_________________________ SUNSI REVIEW COMPLETE FORM 665 ATTACHED OFFICE RII:DRS RII:DRS RII:DRP RII:EICS RII:OFC RII:DRS SIGNATURE *BCC2 SAW4 SRS5 DLG2 SAP1 ATG

NAME BCOLLINS SWALKER SSANDAL DGAMBERONI SPRICE AGODY DATE 8/2/20166 8/8/2016 8/8/2016 8/9/2016 8/9/2016 8/11/2016 8/ /2016 E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO

Letter to Mr. David R. Vineyard from Anthony T. Gody dated August 11, 2016

SUBJECT: EDWIN I. HATCH NUCLEAR PLANT - NRC INSPECTION REPORT

05000321/2016010

DISTRIBUTION

V. McCree, OEDO Region II Regional Coordinator, OEDO

W. Dean, NRR C. Scott, OGC M. Johnson, OEDO

E. Julian, SECY

D. Decker, OCA

All Regions Enforcement Coordinators H. Harrington, OPA

K. Fowler, OI

H. Bell, OIG

L. Casey, NRR

D. Strauss, OGC G. Gulla, OE

L. Wert, RII

M. Franke, RII

B. Collins, RII

S. Sandal, RII

C. Rapp, RII A. Gody, RII

R. Hannah, RII

J. Ledford, RII

J. Pelchat, RII

S. Price, RII D. Gamberoni, RII

L. Gibson, RII

OEMAIL Resource

RidsNrrDirs Resource

Public

Enclosure U.S. NUCLEAR REGULATORY COMMISSION

REGION II

Docket No.: 05000321

License No.: DPR-57

Report No.: 05000321/2016010

Licensee: Southern Nuclear Operating Company, Inc.

Facility: Edwin I. Hatch Nuclear Plant, Unit 1

Location: Baxley, GA 31513

Dates: February 22 - June 30, 2016

Inspectors: B. Collins, Reactor Inspector

Approved by: Shakur A. Walker, Chief Engineering Branch 3

Division of Reactor Safety

SUMMARY IR 05000321/2016010; February 22, 2016 through June 30, 2016; Edwin I. Hatch Nuclear Plant, Unit 1; In-Service Inspection Report.

This report covered a follow-up inspection of unresolved item 05000321/2016001-01 by one

regional inspector. One NRC-identified non-cited violation (NCV); and one apparent violation

(AV) which is being considered for escalated enforcement action in accordance with the NRC Enforcement Policy, are documented in this report. The significance of inspection findings are indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red) and determined using Inspection Manual Chapter (IMC) 0609, "Significance Determination Process" (SDP)

dated June 19, 2012. The cross-cutting aspects are determined using IMC 0310, "Aspects

within the Cross-Cutting Areas," dated December 4, 2014. All violations of NRC requirements

are dispositioned in accordance with the NRC's

Enforcement Policy dated August 1, 2016. The NRC's program for overseeing the safe operations of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Rev. 5.

NRC-Identified and Self-Revealing Findings

Cornerstone: Initiating Events

  • AV: The NRC identified an AV of 10 CFR 50.9, "Completeness and Accuracy of Information," for the licensee's failure to provide data to the NRC that was accurate in all material aspects. Specifically, on two occasions (October 1995, May 2000), the licensee

stated that weld 1B31-1RC-12BR-E-5 had been modified with a full-structural weld overlay

(FSWOL), when in fact it had only been modified with a less robust design overlay (leak

barrier). The NRC approved the licensee's reques

ts/proposed alternatives in part based on the inaccurate characterization of the welds. The licensee has since installed the FSWOL and entered the issue into the corrective action program as CR 10197850.

The NRC is considering escalated enforcement on the basis that had the licensee provided

accurate information, it would likely have caused the NRC to reconsider a regulatory position. (Section 1R08)

system N2E nozzle. The licensee has since repaired the flaw, completed all required post-

repair examinations, and entered this issue entered this into their corrective action program

as CR 10247856.

The performance deficiency was more than minor because it was associated with the

Equipment Performance attribute of the Initiating Events cornerstone and adversely affected the cornerstone objective of limiting the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. The inspectors screened this finding using IMC 0609, Appendix A, "The Significance Determination Process (SDP) For Findings At-Power", dated June 19, 2012. Because after

a reasonable assessment of degradation, the finding could neither result in exceeding the

RCS leak rate for a small LOCA, nor likely affected other systems used to mitigate a LOCA

resulting in a total loss of their function, the finding screened as Green. This finding has a cross-cutting aspect of Challenge the Unknown in the area of Human Performance (H.11)

3 because upon discovery of a less robust configuration of the N2E nozzle overlay, the licensee failed to consider the implications on the flaw that had existed in that component since 1988. (Section 1R08)

REPORT DETAILS

1. REACTOR SAFETY

Cornerstones: Initiating Events, Barrier Integrity, and Mitigating Systems

1R08 Inservice Inspection Activities (71111.08)

.1 URI 05000321/2016001-01, Reactor Coolant System N2E Weld Flaw

a. Inspection Scope

In Inspection Report 05000321/2016001, the inspectors identified an unresolved item

(URI) associated with a flaw in the 1B31-1RC-12BR-E-5 ("N2E") safe end-to-nozzle weld of the reactor coolant system (RCS).

In July 2015, the licensee submitted a proposed alternative to the American Society of

Mechanical Engineers (ASME) Code, HNP-ISI-ALT-15-01 (ADAMS Accession Number

ML15183A354), to install a full-structural weld overlay (FSWOL) on the N2E nozzle.

This proposed alternative was approved by the NRC in December 2015 (ADAMS Accession Number ML15349A973). The licensee implemented this proposed alternative during the February 2016 refueling outage (1R27). After removing all but 1/16" of the

existing overlay, the licensee performed a liquid penetrant examination and noted a pair

of linear indications. Subsequently, the licensee determined that these indications were

actually a single indication, and that it exceeded allowable size limitations according to ASME Code. Upon further review, the licensee realized that these indications were potentially the result of growth of an inner-diameter, surface-connected intergranular

stress corrosion cracking (IGSCC) flaw found in 1988. On April 14, 2016, the licensee

submitted Licensee Event Report (LER) 05000321/2016-003, "Reactor Coolant System Piping Has Unacceptable Weld Indication Discovered During Refueling Outage," as a result of the discovery, due to a principal safety barrier being seriously degraded. The licensee has repaired the flaw, installed the full-structural weld overlay, and completed

all required post-installation examinations. The URI was opened to allow the inspectors

to determine whether the licensee performed all required examinations of the N2E

nozzle between 1988 and 2016, and whether the flaw exceeded minimum wall

limitations at some point during prior operation.

The inspectors identified one apparent violation (AV) with two examples, and one non-

associated Green NCV. Both are described below in 1R08.b. Accordingly, URI 05000321/2016001-01 and LER 05000321/2016-003 have been closed.

b. Findings

(i) Inaccurate Information Provided Regarding N2E Nozzle Weld Overlay

Introduction: The NRC identified an AV of 10 CFR 50.9, "Completeness and Accuracy of Information," for the licensee's failure to provide data to the NRC that was accurate in all material aspects. Specifically, on two occasions (October 1995, May 2000), the licensee stated that the N2E nozzle weld had been modified with a FSWOL, when in fact it had

only been modified with a less robust design overlay (leak barrier). The NRC has not

made an enforcement decision for this AV.

5 Description: In October 1988, during refueling outage 1R11, the licensee performed an ultrasonic examination (UT) on the N2E nozzle weld and identified an indication in the weld. The licensee evaluated the indication and determined that it was unacceptable by ASME Section XI criteria. In November 1988 (still 1R11 outage), the licensee installed a

"design" weld overlay (leak barrier) consistent with paragraph 4.4.2 of NUREG-0313

Revision 2, "Technical Report on Material Selection and Processing Guidelines for BWR

Coolant Pressure Boundary Piping," (ADAMS Accession Number ML031470422).

At the time, the acceptable inspection methodology was delineated in GL 88-01, "NRC Position on IGSCC in BWR Austenitic Stainless Steel Piping," (ADAMS Accession

Number ML031430193). The licensee appropriately classified the N2E weld as a

Category E weld according to this guidance, and as such, the weld was to be inspected

the following refueling outage and then every other refueling outage thereafter. The licensee completed the required examinations in 1R12 (March 1990), 1R13 (October 1991) and 1R15 (October 1994) and noted no appreciable change in flaw geometry

through these three exams.

On October 17, 1995, the licensee submitt

ed their 3rd 10-year Interval Inservice Inspection (ISI) Program to the NRC. In that

letter, the licensee detailed their plan to revise the frequency of the N2E examinations from every-other-outage to once-per-10-

years, and stated that one of the bases for this decision was that the overlay was a

"standard" overlay. This information was not accurate, in that the overlay was, in fact, a

less robust "design" overlay. In September 1997, on the basis of the information

submitted, the NRC approved

the licensee's proposed plan.

On June 17, 1999, the NRC sent a letter to the Boiling Water Reactor Vessel and

Internals Program (BWRVIP) Chairman which stated that several plants, including Hatch

Unit 1, were scheduled for fall 1999 outages, and that deferral of the required exams

would be acceptable provided certain criteria were met. One of the criteria was that "The overlay for which deferral is applied meets GL 88-01 or ASME Code Case N-504 (full structural overlay) as opposed to a temporary duty (leakage barrier) overlay."

On May 30, 2000, the licensee submitted a letter to the NRC requesting deferral of the

N2E exam on the basis of the NRC's June 1999 letter. In this letter, the licensee stated

that "[The N2E weld overlay was] designed and applied as full structural weld overlay." This information was not accurate, in that the overlay was, in fact, a "design" overlay. In October 2000, on the basis of the information submitted, the NRC approved this

approach for one refueling cycle (1R19 to 1R20).

Analysis: The licensee's failure to provide information required by the Commission's regulations, orders and license conditions that was complete and accurate in all material

aspects was a violation of NRC requirements. The NRC determined that this violation

was not associated with a common performance deficiency.

The ROP's significance determination process does not specifically consider the regulatory process impact in its assessment of licensee performance. Because the regulatory process was affected, it is necessary to address this violation which impeded

the NRC's ability to regulate using traditional enforcement. Using the examples provided

in Section 6.9.c.1 of the NRC Enforcement Policy, the NRC is considering escalated

enforcement on the basis that had the licensee provided accurate information, it would

likely have caused the NRC to reconsider a

regulatory position. Specifically, the licensee submitted information to the NRC stating that the N2E nozzle weld overlay was a "standard" overlay, when in fact, it was a less robust "design" overlay. Traditional

enforcement violations are not assessed for cross-cutting aspects.

6 Enforcement: Title 10 CFR 50.9, "Completeness and Accuracy of Information," states, in part, that information required by the Commission's regulations, orders, and license conditions shall be complete and accurate in all material aspects. Contrary to the above, on two occasions (October 17, 1995 and May 30, 2000), the licensee failed to provide

information that was complete and accurate in all material aspects. Specifically, the

licensee stated that the N2E nozzle weld overlay was a "standard" overlay, when in fact,

it was a less robust "design" overlay. These submittals were material to the NRC in that

they were instrumental in the NRC's

approval of the licensee's requests for

relief/proposed alternative. Had the correct information been provided, it would have likely caused the NRC to reconsider its regulatory position. Compliance was restored in

March 2016 when the licensee installed the "standard" (FSWOL) overlay.

No enforcement is being issued at this time because the NRC has not made a final enforcement decision. The licensee entered this issue into their corrective action program (CAP) as CR 10197850. This violation is being treated as an AV pending a

final enforcement determination. (AV 05000321/2016010-01, "Inaccurate Information

Provided Regarding N2E Nozzle Weld Overlay")

(ii) Failure to Identify N2E Nozzle Weld Through-Wall Flaw

Introduction: The inspectors identified a Green NCV of 10 CFR 50 Appendix B Criterion XVI, "Corrective Actions," for the licensee's failure to promptly identify a condition

adverse to quality regarding a through-wall flaw in safe end-to-nozzle weld of the RCS

N2E nozzle.

Description: On April 21, 2015, the licensee was preparing for the upcoming refueling outage and noted that the N2E weld overlay configuration did not match others of similar

original construction. Specifically, the N2E weld was thought to be a "standard" overlay

(FSWOL); however, was discovered to be a less robust "design" overlay (leak barrier). The licensee entered the issue into the CAP as CR 10058892 and decided that in order to obtain full coverage for the non-destructive examination in accordance with ASME

Section XI requirements (for the 4

th 10-year ISI interval), they needed to install a FSWOL. The licensee planned this activity for the upcoming 1R27 outage (February

2016). On July 2, 2015, the licensee submitted a letter to the NRC (ML15224B464)

requesting approval for the proposed alternative (FWSOL), and on December 18, 2015, the NRC issued the approval SER (ML15349A973).

In February 2016, when installing the new FSWOL, the licensee identified two small,

axial, linear indications - each of which

was unacceptable by ASME criteria. In the follow-on corrective actions, the licensee determined that: (1) these two flaws were actually one flaw, (2) it was the same flaw that had been previously identified in October 1988, and (3) it had since grown through the entire thickness of the original weld and

into the overlay material (through-wall).

Upon review of the licensee's corrective actions in CR 10058892, the inspectors identified that the licensee had only focused on addressing the non-destructive examination requirements associated with the 10-year ISI interval, and no consideration was given to the fact that the actual configuration was less robust than originally thought.

Thus, the licensee also failed to consider the current condition of the flaw that existed in

the N2E safe end-to-nozzle weld since October 1988.

As part of their investigation, the licensee sent the UT examination data from the previous exam (1R22, February 2006) to EPRI for further analysis. EPRI determined

that although the licensee's exam was adequate in all respects using 2006 technology

7 and requirements, with EPRI's updated technology and experience, the data suggested that the crack had already grown into the overlay material at that time.

Analysis: The failure of the licensee to promptly identify a nonconformance (through-wall

flaw in ASME Class 1 RCS piping) was a performance deficiency. The performance

deficiency was more than minor because it was associated with the Equipment

Performance attribute of the Initiating Events cornerstone and adversely affected the

cornerstone objective of limiting the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. The inspectors screened this finding using IMC 0609, Appendix A, "The Significance

Determination Process (SDP) For Findings At-Power," dated June 19, 2012. Because

the finding involved the potential for a Loss of Coolant Accident (LOCA), further

evaluation using Exhibit 1, "Initiating Events Screening Questions" was required. Because after a reasonable assessment of degradation, the finding could neither result in exceeding the RCS leak rate for a small LOCA, nor likely affected other systems used to mitigate a LOCA resulting in a total loss of their function, the finding screened as

Green. This finding has a cross-cutting aspect of Challenge the Unknown in the area of

Human Performance (H.11) because upon discovery of a less robust configuration of the N2E nozzle overlay in April 2015, the licensee failed to consider the implications on the flaw that had existed in that component since 1988.

Enforcement: Title 10 CFR 50 Appendix B Criterion XVI, "Corrective Actions," states, in part, that "Measures shall be established to assure that conditions adverse to quality,

such as failure, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected." Contrary to the above, on April 21, 2015, the licensee failed to promptly identify a nonconformance associated with

an ASME Class 1 component (through-wall flaw in the N2E nozzle weld, which

exceeded ASME Section XI limits, as required by 10 CFR 50.55a). The potential safety

consequence of operating at full power with this type of ASME nonconformance is a challenge to the integrity of the reactor coolant pressure boundary, which increases the likelihood of a LOCA. Upon discovery of the flaw condition in February 2016, the

licensee entered the condition into their CAP as CR 10058892 and installed the

appropriate FSWOL, which restored compliance. The licensee has entered this issue into their CAP as CR 10247856. This violation is being treated as an NCV consistent

with Section 2.3.2 of the Enforcement Policy. (NCV 05000321/2016010-02, "Failure to

Identify N2E Nozzle Weld Through-Wall Flaw")

4. OTHER ACTIVITIES

4OA6 Meetings

On July 14, 2016, the inspectors presented the inspection results to Mr. James Collins,

Site Licensing, of your staff. The inspectors confirmed that all proprietary information reviewed during the inspection was returned and that none of the potential report input

discussed was considered proprietary.

ATTACHMENT: SUPPLEMENTARY INFORMATION

Attachment KEY POINTS OF CONTACT

Licensee J. Collins, Site Licensing Manager

A. Gordon, Site ISI Program Engineer

NRC B. Collins, Reactor Inspector D. Hardage, Senior Resident Inspector

D. Retterer, Resident Inspector

LIST OF ITEMS OPENED, CLOSED, DISCUSSED AND UPDATED

Opened 05000321/2016010-01 AV Inaccurate Information Provided Regarding N2E Nozzle

Weld Overlay

Closed 05000321/2016001-01 URI Reactor Coolant System N2E Weld Flaw

05000321/2016003 LER Reactor Coolant System Piping Has Unacceptable Weld Indication Discovered During Refueling Outage

Opened and Closed 05000321/2016010-02 NCV Failure to Identify N2E Nozzle Weld Through-Wall Flaw

LIST OF DOCUMENTS REVIEWED

Corrective Action Documents 263280, Apparent Cause Determination: Failure to Adequately Monitor and Repair a Defect in

1B31-1RC-12BR-E-5, dated 3/25/16

CR10058892: 1B31 Safe End Nozzle Welds, dated 4/21/15 CR10197850: Incorrect Information Submitted to NRC, dated 3/16/16 CR10247856: Violation of 10 CFR 50 Appendix B Criterion XVI, dated 7/13/16

Work Orders/Work Requests: SNC685755, Work Order: Install Full-Structural Weld Overlay on N2E Nozzle (1B31-1RC-12BR-

E-5), dated 7/17/2015

Miscellaneous Documents: HL-5045, Letter from J. T. Beckham, Jr. to Nuclear Regulatory Commission, "Edwin I. Hatch

Nuclear Plant, Third 10-Year Interval Inservice Inspection Program," dated October 17, 1995

HL-5952, Letter from H.L. Sumner, Jr. to Nuclear Regulatory Commission, "Edwin I. Hatch Nuclear Plant, Third 10-year Interval Inservice Inspection Program, Adoption of BWRVIP-75," dated June 23, 2000

NL-15-1146, Letter from C.R. Pierce to Nuclear Regulatory Commission, "Edwin I. Hatch

Nuclear Plant - Unit 1, Proposed Alternative in Accordance with 10 CFR 50.55a (z)(1)

Application of Dissimilar Weld Full-Structural Weld Overlays," dated July 2, 2015 NL-16-0421, Letter from C.R. Pierce to Nuclear Regulatory Commission, "Edwin I. Hatch Nuclear Plant - Unit 1, Full Structural Weld Overlays on Reactor Recirculation and Residual

Heat Removal Systems, Nondestructive Examination Results - Spring 2016 Outage (1R27),"

dated March 17, 2016

NL-5940, Letter from H.L. Sumner, Jr. to Nuclear Regulatory Commission, "Edwin I. Hatch

Nuclear Plant - Unit 1, Reactor Coolant System (RCS) Weld Overlay Examinations," dated May 30, 2000