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.
