The inspectors identified an
NCV of
10 CFR 50.59, Changes, Tests, and Experiments, which had very low safety significance. Specifically, the licensee failed to include non-seismically designed piping outside of the turbine building watertight enclosures as a potential source of
internal flooding in a 50.59 evaluation. The licensee entered the issue into their corrective action program, performed an operability evaluation, and initiated corrective actions. Because this issue affected the NRC\'s ability to perform its regulatory function, it was evaluated using the traditional enforcement process. With the assistance of the NRC Regional Senior Reactor Analyst (
SRA), the inspectors determined from the
initiating events evaluation in the phase one and phase three screenings that the underlying technical issue was of very low safety significance (Green). In accordance with the
Enforcement Policy, the violation was therefore classified as a
Severity Level IV violation. The inspectors determined that there was no cross cutting aspect to this issue.
