The team identified an apparent violation of
10 CFR 50.59 requirements for the licensee\'s failure to perform a written safety evaluation and receive NRC approval prior to implementing changes to the facility in 1992 which involved draining, and maintaining drained, a significant segment of containment
sump safety injection recirculation piping during normal plant operations. This change resulted in the failure to maintain the safety injection piping full of water in accordance with the
Updated Final Safety Analysis Report. This represented an unreviewed safety question since it increased the probability of a malfunction of equipment important to safety previously evaluated in the safety analysis report. In accordance with
Inspection Manual Chapter 0612, Appendix B, Issue Disposition Screening, the team determined that traditional enforcement applied because this finding may have impacted the NRCi12s ability to perform its regulatory function. This is an apparent violation pending the results of a predecisional enforcement conference
