The inspectors identified a
Severity Level IV, Non-Cited Violation of
10 CFR 50.59(d)(1) for the licensee's failure in September 2002 to perform a safety evaluation of the removal of the internals of the
auxiliary feedwater (
AFW) common recirculation line
check valve, AF-117. Specifically, the licensee screened out' adverse changes made concerning the function and operation of all four
AFW pumps. In this case, an automatic passive design feature of the
AFW recirculation line piping was being made unavailable and the function was being changed to operation of an untested, nonsafety-related, active component--the
AFW common recirculation line relief valve AF-4035--and it was being supplemented through the use of
manual operator actions. This change warranted a
10 CFR 50.59 safety evaluation to determine if the changes met the criteria requiring a licensee amendment.
Because the issue potentially affected the NRC's ability to perform its regulatory function, this finding was evaluated using the traditional enforcement process. This finding was determined to be more than minor because the inspectors could not reasonably determine that the original change would have ultimately required NRC approval. The inspectors completed a Significance Determination Review using
IMC 0609, Appendix A "Significance Determination of Reactor Inspection Findings for At Power Situations." Using the Phase 1 Screening worksheet the finding was determined to be of very low safety significance (Green) since the finding did not represent an actual loss of safety function for greater than the Technical Specification allowed outage time. Comparing this item to the examples in
NUREG 1600, Supplement I, this finding is similar to Item D.5, "Violations of
10 CFR 50.59 that do not involve circumstances in which a change that required prior Commission approval would not be found acceptable had the approval been sought." As a result, the issue was considered to be of very low safety significance and was dispositioned as a
Severity Level IV, Non-Cited Violation (
NCV).
