The inspectors identified a
Severity Level IV Non-Cited Violation of
10 CFR 50.59 in that the licensee failed to perform an adequate safety evaluation review for changes made to the facility as described in the
Updated Final Safety Analysis Report (
UFSAR). Specifically, the licensee adversely changed the description in the
UFSAR of the license basis function of the recirculation pump runback in that the recirculation runback feature could no longer prevent a reactor
scram if a
feedwater pump tripped. Within the
10 CFR 50.59 evaluation, the licensee failed to provide a basis for why this malfunction of the recirculation pumps runback logic (equipment important to safety) did not present more than a minimal increase in the likelihood of occurrence of a malfunction of a Structures, Systems, and Components (
SSC) important to safety
Because the issue affected the NRCs ability to perform its regulatory function, this finding was evaluated using the traditional enforcement process. The finding was determined to be more than minor because the inspectors could not reasonably determine that the
UFSAR change, which adversely affected equipment important to safety, would not have ultimately required NRC approval. The finding was determined to be of very low safety significance (Green) because the recirculation runback feature was not a mitigating function.
