05000255/FIN-2015012-01
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Finding | |
|---|---|
| Title | Inaccurate/Incomplete Information Submitted For Relief Request 4-18 |
| Description | An apparent violation (AV) of Title 10 of the Code of Federal Regulations (CFR) 50.9 was identified by the licensee, related to a failure to provide information that was complete and accurate in all material respects to the NRC in letter PNP 2014-015, Relief Request (RR) Number 4-18 - Proposed Alternative Use of Alternate ASME [American Society of Mechanical Engineers] Code Case N-770-1 Baseline Examination. Specifically, in this document the licensee stated, In the unlikely case that crack initiation were to occur, crack growth calculations considering primary water stress corrosion cracking (PWSCC) as the failure mechanism demonstrate that the hot leg drain nozzle weldment satisfies ASME Code acceptance criteria for 60 effective full power years [EFPY] for a circumferential flaw, and more than 34 years for an axial flaw. However, this statement was not correct or accurate in that, the ASME Code acceptance criteria were not satisfied for 60 EFPY for a circumferential flaw and 34 years for an axial flaw, where correct information was 20 EFPY for a circumferential flaw, and 11.3 years for an axial flaw. This AV was not an immediate safety concern because the licensee demonstrated an adequate basis for continued operability of the nine affected primary coolant system (PCS) welds. The licensee corrective actions for this AV included completion of an operability evaluation, submittal of a corrected analysis to the NRC, and entering this issue into the Corrective Action Program (CAP) (CR-PLP-2015-03441). If the NRC was provided with the correct information in letter PNP 2014-015, where the affected welds satisfied ASME Code acceptance criteria (i.e., 75 percent through-wall) for only 20 effective full power years for a circumferential flaw, and 11.3 years for an axial flaw, the NRC would not likely have approved RR 4-18 and, as a minimum, would have requested additional supporting analysis (e.g., required substantial further inquiry). Further, the need for substantial further inquiry was illustrated by the licensees subsequent decision in RR 4-21 to abandon the prior analytical approach used in RR 4-18. The inspectors evaluated the underlying technical issue in accordance with the SDP to determine the risk significance of this AV. The issue of concern was of more than minor significance because it was similar to the not minor if aspect of Example 3j in IMC 0612, Appendix E, Example of Minor Issues. Specifically, the erroneous information provided in letter PNP 2014-015 resulted in a condition in which there was a reasonable doubt on the operability of the systems and components that were the subject of the evaluation and dissimilar from the minor because aspect of this example since the impact of the error for the operability of nine PCS welds was not minimal. In addition, the performance deficiency was determined to be more than minor because it was associated with the Initiating Event Cornerstone attribute of Equipment Performance and adversely affected the Cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions. The inspectors evaluated the finding in accordance with IMC 0609, Significance Determination Process, Attachment 0609.04, Phase 1 Initial Screening and Characterization of Findings, Table 3, for the Initiating Events Cornerstone, and IMC 0609, Appendix A, The SDP for Findings At- Power. Because the licensee was able to demonstrate operability of the nine PCS welds susceptible to PWSCC, the inspectors answered No to questions A.1 and A.2, of Exhibit 1, Initiating Events Screening Questions, identified in Appendix A of IMC 609 and, as a result, the finding screened as having very low safety significance (Green). No cross-cutting aspect was assigned because this Green finding was identified by the licensee. |
| Site: | Palisades  |
|---|---|
| Report | IR 05000255/2015012 Section 1R15 |
| Date counted | Sep 30, 2015 (2015Q3) |
| Type: | TEV: Severity level III |
| cornerstone | Initiating Events |
| Identified by: | Licensee-identified |
| Inspection Procedure: | IP 71111.15 |
| Inspectors (proximate) | A Nguyen D Hills M Holmbergc Pedersona Nguyene Duncan J Boettcher J Cassidy J Jandovitz M Holmberg T Taylor V Myers |
| Violation of: | 10 CFR 50.9 |
| INPO aspect | |
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Finding - Palisades - IR 05000255/2015012 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Palisades) @ 2015Q3
Self-Identified List (Palisades)
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