The inspectors identified a violation of
10 CFR Part 50, Appendix B, Criterion XVI, Corrective Actions, for the failure to implement corrective actions for a
condition adverse to quality. Specifically, the licensee developed a corrective action to evaluate the condition of existing
boric acid leaks. However, the effort failed to identify and evaluate multiple existing
boric acid leaks on safety-related components, including some that had deteriorated since initial discovery. The licensee entered this deficiency into their corrective action program as Condition Report
CR-WF3-2007-3951. This finding was more than minor because, if left uncorrected, it would have become a more significant safety concern. Specifically, some unchecked
boric acid leaks may have worsened and corroded safety-related equipment. Using the Manual Chapter 0609, \"
Significance Determination Process,\" Phase 1 Screening Worksheet, the finding had very low risk significance because it was a qualification deficiency confirmed not to result in loss-of-operability in accordance with NRC Manual Chapter Part 9900, Technical Guidance, \"
Operability Determination Process for Operability and Functional Assessments.\" This finding had a crosscutting aspect in the Human Performance area, Work Practices component, because engineers failed to implement proper error prevention techniques when identifying
boric acid leaks for additional review
H.4(a) (Section 1R04)