05000255/FIN-2013002-05
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Finding | |
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| Title | Failure to Take Corrective Action to Prevent Recurrence of CRDM Pressure Boundary Leakage |
| Description | A self-revealing finding of very low safety significance (Green) with associated NCV of 10 CFR Part 50, Appendix B, Criterion XVI, and Technical Specification (TS) 3.4.13, Primary Coolant System (PCS) Operational Leakage, was identified for failure to take corrective actions to prevent recurrence of Control Rod Drive Mechanism (CRDM) cracking and leakage, a significant condition adverse to quality (SCAQ). Specifically, for Criterion XVI the licensee failed to include the internal CRDM housing weld build-up area within the scope of corrective actions taken for a 2001 CRDM through wall leak on CRDM-21, caused by transgranular stress corrosion cracking (TGSCC). Subsequently, a through wall leak recurred in the weld build-up area on CRDM-24 in 2012 due to TGSCC. As a result, the licensee operated with PCS pressure boundary leakage, which is not allowed by TS 3.4.13. Further, because the licensee was not aware that the leakage was PCS pressure boundary leakage, the licensee did not implement the associated TS action statement. The licensee replaced CRDM-24 upper housing and entered the issue into their corrective action program as CR-PLP-2013-01134. Additional corrective actions are described in NRC Inspection Report 05000255/2012012. The inspectors determined that this issue was more than minor in accordance with IMC 0612, Appendix B, Issue Screening, because it was associated with the Initiating Events Cornerstone attribute of equipment performance and adversely affected the cornerstone objective to limit the likelihood of events that upset plant stability. Specifically, the licensee did not take adequate corrective actions to prevent recurrence of leakage in CRDM housings, which represents pressure boundary leakage. The inspectors determined this finding was of very low safety significance (Green) because the leak would not have exceeded the reactor coolant system leak rate for a small LOCA and could not have likely affected other systems used to mitigate a LOCA resulting in a total loss of their function. Specifically, the slow rate of change for leakage for TGSCC in type 316 stainless steel will experience leakage rates well below a small break LOCA, which would be observed through the crack, alerting operators to take action to shut down the plant prior to experiencing a component rupture. The cause of this finding, non-conservative decision making, occurred over 10 years ago and is well outside of the nominal 3 year period in IMC 0612 for cross-cutting aspects. Therefore, this is not indicative of current performance, because no other opportunities to identify the issue occurred during the previous 3-year period. However more recently, the licensee exhibited non-conservative decision making with respect to addressing the potential for CRDM housing cracking and leakage during the recent root cause (Section 4OA2.4 (b.2) of this report), resulting in another finding. This cross-cutting aspect will be captured through the other finding. |
| Site: | Palisades  |
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| Report | IR 05000255/2013002 Section 4OA2 |
| Date counted | Mar 31, 2013 (2013Q1) |
| Type: | NCV: Green |
| cornerstone | Initiating Events |
| Identified by: | Self-revealing |
| Inspection Procedure: | IP 71152 |
| Inspectors (proximate) | C Zoia S Sheldon M Phalen J Lennartz K Walton M Jones T Taylor A Scarbeary E Sanchez-Santiago D Alley |
| Violation of: | 10 CFR 50 Appendix B Criterion XVI Technical Specification |
| INPO aspect | |
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Finding - Palisades - IR 05000255/2013002 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Palisades) @ 2013Q1
Self-Identified List (Palisades)
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