No Color: The inspectors identified a
Severity Level IV non-cited violation of
10 CFR 50.59, Changes, Tests, and Experiments. Specifically, the licensee implemented proceduralized departures from the approved station technical specifications (TS) without the required NRC approval in procedures
AP-13.0, Turbine Building Flooding, revision 13, and FCA 6.01, Uncontrollable Turbine Building Flooding, revision 2. This finding was evaluated using traditional enforcement since it impacted or impeded the regulatory process in that the licensee improperly used the
10 CFR 50.59, Changes, Tests, and Experiments, process to incorporate operator actions inconsistent with the TS. This finding was of more than minor safety significance because the procedure changes improperly bypassed the required NRC review and approval prior to implementation. The unapproved procedural actions would only be involved at the end of a very rare accident sequence. Given the time during the accident sequence in which these actions were to be accomplished, the actions were not a determent to core damage. Therefore, the violation was of very low safety significance. The finding is identified as
Severity Level IV because the noncompliance is not considered to be of more than very low significance based on risk.
