The team identified a
Severity Level IV non-cited violation of
10 CFR 50.59(c)(2), Changes, Tests, and Experiments, for the licensees failure to obtain a license amendment, as specified by
Nuclear Energy Institute (NEI) 96-07 Section, 4.3.2, prior to implementing a change that increased the likelihood of a malfunction of a safety-related dike. This has been entered into the licensee corrective action program as condition report 1065945. The violation was dispositioned using the traditional enforcement process in accordance with the
NRC Enforcement Policy, Subsection 2.2.2 Revised August 1, 2016, because the issue affected the NRCs ability to perform its regulatory oversight function. The
NRC Enforcement Policy, Section 6.1, Violation Examples for Reactor Operations, Subsection 6.1.d.2 specified that violations of
10 CFR 50.59 which resulted in conditions that were evaluated by the
Significance Determination Process (
SDP) as being of very low safety significance represented a
severity level IV violation. The regional senior reactor analyst performed a screening analysis to determine the significance of the violation. Using very conservative failure frequencies for ductile
iron pipe used in water systems, and a conservative initiating event frequency for an independent simultaneous rainfall capable of filling the dike, the finding was determined to be of very low safety significance. The inspector determined that the detailed risk evaluation confirmed that a
severity level IV violation was appropriate. Crosscutting aspects are not assigned to traditional enforcement violations.