The inspectors identified a
Severity Level IV non-cited violation of 10 CFR 50.59; Changes, Tests, and Experiments. Specifically, Seabrook adversely changed the bases of
Technical Specification (TS) 3.4.10, Structural Integrity, to make it applicable to only the
reactor coolant system pressure boundary piping, and not all American Society of Mechanical Engineers (
ASME) code class piping. This, in effect, changed the intent of
TS 3.4.10 without a license amendment. Following identification of this issue, Seabrook entered the issue into their corrective action program as condition report 06-03108. This finding was addressed using traditional enforcement since it potentially impacted or impeded the regulatory process in that Seabrook used the 10 CFR 50.59 process to change the intent of an existing TS. This is contrary to the regulatory process that allows licensees to make changes without a license amendment provided that licensees comply with the 10 CFR 50.59 process. The finding is more than minor because there was a reasonable likelihood that the change would have required Commission review and approval prior to implementation. The finding is of very low safety significance because it did not require a quantitative assessment based on the shutdown risk mitigation capability of other available equipment.