The team identified a Non-Cited Violation of
10 CFR 50.59, \"Changes, Tests and Experiments.\" Specifically, the license
failed to preform an adequate evaluation of a defacto modification to the plant where the underlying change may have required NRC approva
prior to implementation. The design change involved degraded or missing physical barriers that could result in one or more of the diese
generators failing to fulfill their design function during a tornado. Following discovery, the licensee entered the issue into the corrective actio
program and re-performed the analysis. The licensee also repaired those barriers which were physically degraded. The primary cause of thi
violation was related to the cross-cutting area of human performance as the licensee appeared to selectively choose information from th
guidance document in order to achieve the desired outcome
Because this issue affected the NRC's ability to perform its regulatory function, this finding was evaluated with the traditional enforcemen
process. The finding was determined to be of very low safety significance based on a significance determination process analysis of a loss o
offsite power concurrent with loss of one
emergency diesel generator. (Section 4OA3(3)b.23)
