05000317/FIN-2013004-02
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Finding | |
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Title | Licensee-Identified Violation |
Description | On February 17, 2013, while Unit 2 was in Mode 3 during a refueling outage, CENG personnel identified a pinhole leak at the upper packing leakoff line cap seal weld of pressurizer spray valve 2CV-100F, which constituted RCS pressure boundary leakage. Technical Specifications limiting condition for operation 3.4.13.a, RCS Operational Leakage, limits pressure boundary leakage during plant operation to zero. With any RCS pressure boundary leakage, the technical specifications require the operating unit to be in Mode 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and to be in Mode 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. Contrary to the above, based on review of boric acid walkdown data, RCS pressure boundary leakage existed sometime after the last boric acid walkdown conducted in Unit 2 2011 refueling outage and continued during operation for a time longer than allowed by the technical specifications. The inspectors determined that no performance deficiency existed because CENG satisfactorily tested the component using appropriate non-destructive testing prior to installation, identified the boundary leakage through the use of an prescribed monitoring program (boric acid leakage monitoring) and the monitoring frequency was appropriate for the system location (component location inside containment is inaccessible during reactor operation). The inspectors reviewed LER 2013-001-00 and determined that traditional enforcement applies in accordance with IMC 0612, Section 0612-09 and 0612-13 and Enforcement Policy, Section 2.2.4.d, because a violation of NRC requirements existed without an associated significance determination process performance deficiency. This issue was considered to be a Severity Level IV NCV of Technical Specifications limiting condition for operation 3.4.13.a, in accordance with Enforcement Policy, Section 6.1.d. In addition, the inspectors also evaluated this finding using IMC 0609, Attachment 4, Phase 1 Initial Screening and Characterization of Findings. The inspectors screened the issue and determined that RCS leakage is considered a loss of coolant accident initiator, and evaluated it using the Initiating Event criteria in Appendix A. Assuming worst case degradation, the leakage would not result in exceeding the technical specifications limit for identified RCS leakage (10 gallons per minute) nor would the leakage have likely affected other mitigation systems resulting in a total loss of their safety function. This severity level IV licensee-identified NCV was entered into CENGs CAP as CR-2013-001245. |
Site: | Calvert Cliffs |
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Report | IR 05000317/2013004 Section 4OA7 |
Date counted | Sep 30, 2013 (2013Q3) |
Type: | NCV: Green |
cornerstone | Mitigating Systems |
Identified by: | Licensee-identified |
Inspection Procedure: | |
Inspectors (proximate) | A Rosebrook B Fuller B Scrabeck D Schroeder E Torres G Callaway J Laughlin R Rolph S Kennedy S Pindale |
Violation of: | Technical Specification |
INPO aspect | |
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Finding - Calvert Cliffs - IR 05000317/2013004 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Calvert Cliffs) @ 2013Q3
Self-Identified List (Calvert Cliffs)
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