The inspectors identified a non-cited violation of
10 CFR 50.59 for removing the approved seismic qualification methodology (
WCAP-8110, supplement 9) from the
Updated Final Safety Analysis Report (
UFSAR) without performing a written safety evaluation. This issue is in the licensees corrective action program as
PIP M-07-5016. The failure to perform a written safety evaluation for changes made to the facility as described in the
UFSAR is more than minor because there was a reasonable likelihood that the change requiring a
10 CFR 50.59 written safety evaluation would require Commission review and approval prior to implementation in accordance with
10 CFR 50.59(c)(2). This likelihood is based on the November 21, 1974, NRC Safety Evaluation Report for
WCAP-8110 Supplement 9, which stated the
WCAP is considered an accepted methodology to demonstrate the continued adequacy of ice retention characteristics of the ice baskets when used as a reference for license applications. Removal of this approved methodology from the licensing basis would constitute a change in methodology and would require NRC review and approval. This issue was treated as traditional enforcement because it had the potential for impacting the NRCs ability to perform its regulatory function. It was characterized as a
severity level IV violation because it was evaluated as not having greater than very low safety significance
