A noncited violation of
10 CFR 50.59 was identified for making nine revisions to Procedure
74DP-9CY04, System Chemistry Specification, a procedure described in the
Updated Final Safety Analysis Report between 1998 and 2004. Specifically, the licensee failed to perform evaluations for Revisions 3, 6, 8, 10, 12, 24, 28, 32, and 36 and performed inadequate evaluations for Revisions 10 and 36, to assess the potential impact of the changes on the safety-related components in the
spray pond system. Each of these changes revised
spray pond chemistry parameter limits which were subsequently determined to have contributed to heat exchanger fouling. Failure to adequately evaluate the impact of changes to the Chemistry Control Program was a performance deficiency. Because this violation had the potential to impact the NRC?s regulatory function, and because the associated significance was determined to be Green using Phase 3 of the
significance determination process, this violation is being treated as a
Severity Level IV violation. This issue was entered into the Corrective Action Program under CRDR 2902498. Because this violation was of very low safety significance and has been entered into the corrective action program, it is being treated as a noncited violation consistent with Section VI.A of the Enforcement Policy:
NCV 05000528; 05000529;
05000530/2006011-03, 50.59 Reviews Not Performed or Inadequate for Multiple Changes to
Spray Pond Chemistry Control Procedure.
