05000456/FIN-2012003-03

Finding

Title

Failure to Accomplish Corrective Actions Following Identified Boric Acid Leakage on Reactor Head Penetration No. 77

Description

A finding of very low safety significance (Green) and an associated NCV of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, was identified by the inspectors when licensee personnel failed to accomplish corrective actions following identified boric acid leakage on a reactor head penetration. Specifically, the licensee did not adequately implement corrective actions involving cleaning and removal of boric acid deposits following identified boric acid leakage on Reactor Head Penetration No. 77. The licensee entered this issue into the CAP as IR 1359227 and performed a UT examination of the penetration to confirm that no leakage path existed and a post-cleaning visual examination to confirm no signs of gross degradation. The performance deficiency was determined to be more than minor because the issue was associated with the Equipment Performance attribute of the Initiating Events Cornerstone and adversely affected the cornerstone objective of limiting the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown, as well as power operation. Specifically, the reactor head was returned to service without accomplishing corrective actions to remove all boric acid deposits from the Penetration No. 77 leakage. This resulted in boric acid deposits being left on the reactor head for one operating cycle and masking of potential surface indications from Penetration No. 77 leakage during the subsequent Bare Metal Visual (BMV) examination. Because no gross visual degradation was observed during the BMV examination after cleaning of boric acid deposits and no leakage path was detected during the UT examination of Penetration No. 77 in the A1R16 outage, the inspectors answered No to the SDP Phase I screening question Assuming worst case degradation, would the finding result in exceeding the Tech Spec limit for any RCS leakage or could the finding have likely affected other mitigation systems resulting in a total loss of their safety function assuming the worst case degradation? Therefore, the finding screened as having very low safety significance (Green). This finding had a cross-cutting aspect in the Work Control component of the Human Performance cross-cutting area because the licensee did not appropriately plan the reactor work activity to repair and clean the mechanical connection on Penetration No. 77 by incorporating job site conditions including risk insights associated with potentially washing down boric acid deposits below the reactor head insulation onto the reactor head.

03
Site:	Braidwood
Report	IR 05000456/2012003 Section 1R08
Date counted	Jun 30, 2012 (2012Q2)
Type:	NCV: Green
cornerstone	Initiating Events
Identified by:	NRC identified
Inspection Procedure:	IP 71111.08
Inspectors (proximate)	M Perry R Ng R Walton T Go A Garmoe A Shaikh B Metrow E Duncan J Benjamin M Holmberg
CCA	H.5, Work Management
INPO aspect	WP.1
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v • d • e

Finding - Braidwood - IR 05000456/2012003

12(1)12(0)12(1)12(1)12(0)12(1)12(1)12(1)12(1)1(0)2(6)3(8)4(6)5(8)7(4)8(2)9(0)12(1)402(0)403(0)404(1)501(0)503(0)9(0)22(0)1(0)15(0)

IR 05000456/2012003: 1 2 3 4 5 6 7 8

Finding List (Braidwood) @ 2012Q2

CCA Matrix: 2012Q2

	Q	CCA	Title
05000456/FIN-2011004-04	2011Q3		Operability Evaluation Not Performed in Accordance with Station Standards
05000456/FIN-2011004-06	2011Q3		Modification of the Auxiliary Feedwater System Without Prior NRC Approval
05000456/FIN-2011004-02	2011Q3		Use of Mesh Strainer Bags in Auxiliary Building Floor Drains
05000456/FIN-2011008-02	2011Q3		Permanent Lead Shielding added to Safety Injection and Chemical Volume and Control System Piping.
05000456/FIN-2011008-01	2011Q3		Embedment Plate Design Deficiencies
05000456/FIN-2011004-01	2011Q3	H.2	Failure to Adhere to Standards of Outdoor Secured Material Zones
05000456/FIN-2011004-03	2011Q3		Failure to Control High Energy Line Break Barrier Doors
05000456/FIN-2011004-05	2011Q3	P.2	Asiatic Clams Identified in the Essential Service Water System Supply to the Auxiliary Feedwater System
05000456/FIN-2011004-07	2011Q3	P.5	Modification of the Auxiliary Feedwater System Without Prior NRC Approval
05000456/FIN-2011004-08	2011Q3	H.7	Failure to Follow Maintenance Rule Procedure
05000456/FIN-2011004-09	2011Q3		Design of Auxiliary Feedwater System Included Voids in Safety-Related Alternate Suction Flow Paths
05000456/FIN-2011001-02	2011Q4		Failure to Follow Procedures to Ensure Multi Purpose Canister Design Basis Pressure is Not Exceeded
05000456/FIN-2011005-06	2011Q4	H.7	Failure to Adhere to Maintenance Rule Implementaion Procedures
05000456/FIN-2011005-05	2011Q4	P.5 P.2(b)	Failure to Follow and Establish Adequate Hazard Barrier Impairment Procedures
05000456/FIN-2011005-02	2011Q4		Failure to Evaluate CQ System Performance Against Maintenance Rule Criteria
05000456/FIN-2011001-01	2011Q4		Failure to Perform Adequate Evaluations to Facilitate Independent Spent Fuel Storage Installation Activities
05000456/FIN-2011005-03	2011Q4		Failure to Submit Licensee Event Report Per 10 CFR 50.73(a)(2)(vii)
05000456/FIN-2011005-07	2011Q4		Failure to Perform Adequate Evaluations to Facilitate Independent Spent Fuel Storage Installation Activities
05000456/FIN-2011005-08	2011Q4		Failure to Follow Procedures Adequate Evalations to Facilitate Independent Spent Fuel Storage Installation Activities
05000456/FIN-2011005-04	2011Q4	P.2	Operability Evaluation Not Performed in Accordance with Station Standards
05000456/FIN-2011005-01	2011Q4	H.13	Failure to Maintain Adequate Circulating Water Blowdown Procedure During Liquid Radiological Releases
05000456/FIN-2012002-01	2012Q1		Failure to Maintain Approved Fire Protection Program Regarding Safe Shutdown Fire Damper Qualification
05000456/FIN-2012002-06	2012Q1		Inadequate Safety-Related 4kV Undervoltage Protection
05000456/FIN-2012002-04	2012Q1		Maintenance Rule Performance Monitoring of HELB Dampers
05000456/FIN-2012002-05	2012Q1		Incorrect Classification of Environmental Qualification Zones
05000456/FIN-2012002-03	2012Q1		Failure to Scope Safety-Related HELB Barriers Into the Maintenance Rule
05000456/FIN-2012002-02	2012Q1	P.2	Failure to Promptly Correct Conditions Adverse to Quality
05000456/FIN-2012003-02	2012Q2	H.14	Steam Generator Primary Manway Bolts Examined with Unqualified Procedure
05000456/FIN-2012003-03	2012Q2	H.5	Failure to Accomplish Corrective Actions Following Identified Boric Acid Leakage on Reactor Head Penetration No. 77
05000456/FIN-2012003-04	2012Q2	H.13	Operability Determination Standards Not Followed for HELB Related Structural Issues Identified by the NRC
05000456/FIN-2012007-01	2012Q2	H.14	Non-Conforming Piping Condition Not Corrected
05000456/FIN-2012007-02	2012Q2	H.8	Surveillance Procedure Not Followed
05000456/FIN-2012007-03	2012Q2	P.3	Untimely Completion of a Corrective Action to Prevent Recurrence
05000456/FIN-2012007-04	2012Q2	P.5 P.2(a)	Failure to Follow Corrective Action Program Procedure
05000456/FIN-2012003-05	2012Q2		Licensees Position Regarding TS 3.6.3 Applicability to Main Steam Isolation Valves
05000456/FIN-2012003-06	2012Q2		MSIV Hydraulic System Design
05000456/FIN-2012003-07	2012Q2		Removal of TRM 3.3.y Requirement Via 10 CFR 50.59 Evaluation
05000456/FIN-2012003-01	2012Q2	H.1	Failure to Implement Abnormal Operating Procedures When Entry Conditions Were PresentFailure to Implement Abnormal Operating Procedures When Entry Conditions Were Present

Self-Identified List (Braidwood)

	Q	Title
05000456/FIN-2011005-09	2011Q4	Licensee-Identified Violation
05000456/FIN-2011005-10	2011Q4	Licensee-Identified Violation
05000456/FIN-2011406-01	2011Q4	Security
05000456/FIN-2012003-08	2012Q2	Licensee-Identified Violation

[Braidwood Findings full list]

05000456/FIN-2012003-03

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