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10 CFR 50.59(d)(1) requires, in part, that the licensee shall maintain records of changes in the facility, of changes in procedures, and of tests and experiments made pursuant to paragraph (c) of this section. These records must include a written evaluation which provides the bases for the determination that the change, test, or experiment does not require a license amendment pursuant to paragraph (c)(2) of this section. Contrary to the above, prior to August 28, 2014, the licensee failed to perform an evaluation against the criteria in
10 CFR 50.59(c)(2) for a change to the facility. Specifically, the licensee identified that Licensing Document Change Request 04-F020, performed on March 4, 2005, had changed the
FSAR description of the
auxiliary feedwater system. The new revision stated that portions of the
auxiliary feedwater system, which are not contained within a Seismic Category I structure or installed underground, have been analyzed to show that the probability of being struck by a
tornado missile is sufficiently low and do not require
tornado missile protection. Previously, the
FSAR described that all components of the
auxiliary feedwater system were either enclosed by a Seismic Category I structure or are installed underground. This change had been inappropriately screened out of the 50.59 process in 2005. The licensees 50.59 screening did not recognize that this change to the
FSAR description constituted a de facto change to the design of the facility. Consequently, the licensee failed to perform an evaluation against the criteria in
10 CFR 50.59(c)(2). On August 28, 2014, the licensee recognized the
auxiliary feedwater recirculation lines do not meet the original
FSAR criteria of being protected from
tornado missiles. The licensee initiated PVAR 4568732 to document the lack of
tornado missile protection for the
auxiliary feedwater minimum flow recirculation lines. The licensee performed an immediate
operability determination on August 29, 2014 and determined that there was a reasonable expectation that the
auxiliary feedwater system would provide adequate
decay heat removal following a tornado. The inspectors reviewed the licensees
operability determination and verified that the licensee intends to submit a license amendment request for acceptance of the as-built configuration of the
auxiliary feedwater system. Because the failure to implement the requirements of
10 CFR 50.59 had the potential to impact the NRCs ability to perform its regulatory function, the team evaluated the performance deficiency using traditional enforcement. In accordance with Section 2.1.3.E.6 of the
NRC Enforcement Manual, the inspectors evaluated this finding using the
significance determination process to assess its significance. The finding required a detailed risk evaluation because it involved the failure of two or more trains in a multi-train system. A Region IV senior reactor analyst performed a bounding detailed risk evaluation and determined that the bounding delta-CDF was less than 3.5E-8/year. In accordance with Section 6.1.d of the
NRC Enforcement Policy, this violation is categorized as
Severity Level IV violation because the resulting change was evaluated by the
SDP as having very low safety significance (i.e., Green finding). This issue has been entered into the licensees corrective action program as CRDR 4570021.
