A failure to perform an adequate safety evaluation review as required by
10 CFR 50.59 for changes made to the facility as described in the Updated Safety Analysis Report (
USAR) was self-revealed. In June 2003, the licensee changed the limit and precautions sections of several procedures to specify that
emergency core cooling system (
ECCS) room
sump pumps were not required to be in service for
ECCS and
containment spray equipment operability. However, the
USAR credits the
ECCS sump pumps and their running lights for providing indication of the need for operator action in response to a passive failure in the
ECCS system. The procedure changes were inappropriately categorized as being exempt from the 50.59 process because the changes involved "Managerial or Administrative Procedures." Because the issue affected the NRC's ability to perform its regulatory function, this finding was evaluated with the traditional enforcement process. The finding was determined to be of very low safety significance because, although the procedure changes could have resulted in the operation outside the requirements of technical specification action statements, no loss of function occurred. This was determined to be a
Severity Level IV NCV of
10 CFR 50.59.
