An NRC identified
Severity Level IV violation of
10 CFR 50.71(e), "Maintenance of Records, Making of Reports," was identified for the licensees failure to update the final safety analysis report (
FSAR) after the licensee adopted the improved technical specifications (
ITS). The licensee adoption of
ITS introduced the possibility of a Mode 4 loss of cooling accident (
LOCA), which was an accident of a different type than previously evaluated in the
FSAR. The licensee initiated
PIP O-15-00260 in order to determine future corrective actions. Continued non-compliance does not present an immediate safety concern because the inspectors assessed this as a very low safety significant issue. The licensees failure to update the
FSAR as required by
10 CFR 50.71(e) was a performance deficiency. The performance deficiency impacted the ability of the NRC to perform its regulatory oversight function and was dispositioned using traditional enforcement. Specifically, a failure to update the
UFSAR challenges the regulatory process because it serves as a reference document used, in part, for recurring safety analyses, evaluating license amendment requests, and in preparation for and conduct of inspection activities. This violation was determined to be a
Severity Level IV violation per Section 6.1.d.3 of the
NRC Enforcement Policy, revised July 9, 2013, because the lack of up-to-date information has not resulted in any unacceptable change to the facility or procedures. The
NRC Enforcement Policy also requires disposition of findings in the
significance determination process, which determined the finding was not more than minor. Since this issue was dispositioned using traditional enforcement, there was no cross-cutting aspect associated with this violation.
