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The inspectors identified a Green NCV of TThe inspectors identified a Green NCV of Title 10 of the Code of Federal Regulations (10 CFR) 50, Appendix B, Criterion XVI, Corrective Actions, because between 2007 and 2015, Exelon staff did not promptly identify and correct a deficiency associated with Unit 2 reactor building service water pipe penetration W-3177-C. Specifically, on August 20, 2015, during Exelon staffs investigation of an inspector concern associated with the service water pipe penetration into secondary containment, a leakage path into secondary containment was discovered and was not previously identified and evaluated for impact on operability of Unit 2 secondary containment. Exelon generated issue report (IR) 2544831 to document the newly identified condition. The assessment included a review of previously identified leakage paths that were being tracked in accordance with procedure, previously performed secondary containment drawdown leakage testing, and a comparison to the maximum allowable flow rate leakage area. The assessment concluded that based on the gap that was identified at secondary containment penetration W-3177-C, there was a new total of 1.783 square inches of surface area allowing leakage into the Unit 2 secondary containment. Exelon determined this to be acceptable because calculations for secondary containment drawdown testing allows for up to 33.6 square inches of surface area causing in-leakage into secondary containment. Given 1.783 square inches of total identified leakage being less than the allowable 33.6 square inches, there was reasonable assurance that standby gas treatment system will be able to perform its drawdown function and maintain secondary containment vacuum 0.25 inches of vacuum water gauge in accordance with Technical Specification (TS) 3.6.4.1, Secondary Containment. This performance deficiency was more than minor because it impacted the design control attribute of the Barrier Integrity cornerstone objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. Specifically, Exelons staff failed to identify the degraded penetration seal that impacted the reasonable assurance of Unit 2 secondary containment operability. In accordance with IMC 0609.04, Initial Characterization of Findings, and Exhibit 3 of IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, issued June 19, 2012, the inspectors determined this finding was of very low safety significance (Green) because the finding only represented a degradation of the radiological barrier function provided for the control room, or auxiliary, spent fuel pool, or standby gas treatment system (i.e., secondary containment). This finding had a cross-cutting aspect in the area of Problem Identification and Resolution, Evaluation, because Exelon staff failed to properly evaluate the condition identified in multiple IRs to determine the extent of condition associated with secondary containment water in-leakage. Specifically, between 2007 and 2015, three IRs were generated and a 2012 structural monitoring review documented the service water penetration water in-leakage and the issue was not appropriately evaluated for the potential for a service water pipe through-wall leak or the potential impact on secondary containment.potential impact on secondary containment.  
23:59:59, 30 September 2015  +
05000220  +  and 05000410  +
23:59:59, 30 September 2015  +
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12:57:49, 25 September 2017  +
23:59:59, 30 September 2015  +
Failure to Identify and Correct a Condition Adverse to Quality Associated with Secondary Containment Leakage  +