The inspectors identified a non-cited violation of
10CFR50.59 for failure to obtain a license amendment prior to implementing a change to plant procedures that involved an unreviewed safety question. The unreviewed safety question dealt with extending the availability of non- seismic condenser circulating water piping to perform a safety-related function following a seismic event. This issue is more than minor because it would require NRC review prior to implementation. A subsequent engineering evaluation determined that the non-seismic piping would not collapse or kink, and although it may leak, it will provide the necessary minimal
service water flow function. Since the technical issue was determined to be of very low safety significance, the regulatory significance was categorized as a
Severity Level IV violation.
