A Green (
Severity Level IV) non-cited violation of
10 CFR 50.59 was identified for failure to perform an adequate safety evaluation (
SE) of a change to the facility. Specifically, Entergy's
SE did not adequately evaluate the potential for a malfunction with a different result associated with the elimination of
safety relief valve (
SRV)
accumulator check valve leakage testing. The issue was entered into the corrective action program. An operability evaluation concluded that the equipment was
operable and additional corrective actions are under review.
Entergy's less than adequate
10 CFR 50.59 safety evaluation constitutes a performance deficiency. This finding has been addressed using traditional enforcement since it potentially impacted or impeded the regulatory process in that a required
10 CFR 50.59 evaluation was not adequate. This is contrary to the regulatory process that allows licensees to make changes without a license amendment provided that licensees comply with the
10 CFR 50.59 process. The finding is greater than minor, because there was a reasonable likelihood that the change would have required NRC review and approval prior to implementation. This finding was evaluated using the
SDP for the
mitigating systems cornerstone and was determined to be a finding of very low safety significance (Green), because it did not impact operability of the
SRVs, and was not potentially risk-significant due to possible external events. Because this finding is of very low safety significance and has been entered in Entergy's corrective action program, the violation is being treated as a non-cited violation.
