A non-cited violation of
10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, was identified for failing to adequately identify and correct
ultimate heat sink licensing basis document inaccuracies. The finding is more than minor because the failure to have an accurate description of the
ultimate heat sink (
UHS) in the licensing basis documents had a material impact on licensed activities. In addition, an accurately defined
UHS is necessary to adequately assess plant modifications,
operability determinations, and technical specification entry conditions. This issue was treated as traditional enforcement because it had the potential for impacting the NRCs ability to perform its regulatory function. This finding was characterized as a
Severity Level IV violation because the NRC determined the standby nuclear
service water pond met the requirements of
Regulatory Guide (RG) 1.27 in the Safety Evaluation Report (
SER) and it does not result in a condition evaluated as having low to moderate, or greater safety significance (i.e., white, yellow, or red). This finding has a cross-cutting aspect of corrective action
P.1(c) in the Corrective Action Program component of the Problem Identification and Resolution cross-cutting area because the licensee failed to thoroughly evaluate this issue such that the resolutions addressed all the causes and extent of conditions, as necessary.
