An NRC-identified Green non-cited violation (
NCV) of
10 CFR Part 50.55a, Codes and Standards, was identified for the licensees failure to perform general visual examinations of
moisture barrier material in the reactor containment leak-chase channel test connections in accordance with the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (
ASME BPV Code), Section XI, Subsection
IWE. The licensee performed the required examinations in Unit 1 during the March 2016 refueling outage and initiated corrective actions to revise the Containment Inservice Inspection (
ISI) Plan. The licensee also planned to perform similar examinations in Unit 2 prior to the end of the first containment
ISI period. Additionally, the licensee performed a containment
operability determination to justify continuous operation of the Unit 1 and Unit 2 containment based on the results of all visual examinations, extent of condition activities, and the results of containment integrated leak rate tests. The licensee entered this issue into their corrective action program as action request (
AR) 02038505. The failure to conduct the required visual examination of
moisture barrier material in accordance with the
ASME BPV Code was a performance deficiency (
PD). The
PD was of more than minor significance per IMC-0612, Appendix B, Issue Screening, because the current Containment
ISI Plan did not adequately implement the
ASME BPV Code requirements for the examination of
moisture barriers, and if left uncorrected, it had the potential to lead to a more significant concern. The finding was of very low safety significance (Green) per IMC-0609 because it did not represent an actual open pathway in the physical integrity of the reactor containment and did not involve an actual reduction in function of
hydrogen igniters in the reactor containment. The finding had a cross-cutting aspect of resolution in the problem identification and resolution cross-cutting area because the licensee did not take effective corrective actions to implement the
ASME BPV code requirements in the Containment
ISI Plan when a reasonable opportunity was available through the review of NRC
Information Notice (IN) 2014-07.
