The inspectors identified a
Severity Level IV Non-Cited Violation associated with the failure to perform an adequate safety evaluation review as required by
10 CFR 50.59 for changes made to the facility as described in the Updated Safety Analysis Report (
USAR). Specifically, the licensee deleted Technical Requirements Manual (
TRM) Surveillance Requirement TSR 3.5.1.3, which required that a quarterly flowrate test be performed for the charging pumps, but failed to provide a basis for the determination that this deletion was acceptable without a license amendment. The safety evaluation failed to address the purpose of the flowrate test which was to ensure that one changing pump could sufficiently compensate for the addition of positive reactivity from the decay of
xenon after a
reactor trip. Because the
Significance Determination Process (
SDP) is not designed to assess the significance of violations that potentially impact or impede the regulatory process, this issue was dispositioned using the traditional enforcement process in accordance with Section IV of the
NRC Enforcement Policy. However, the results of the violation, that is, the failure to evaluate the deletion of TSR 3.5.1.3 from the
TRM, were assessed using the
SDP. The team considered this issue of more than minor significance, because if left uncorrected, the finding could become a more significant safety concern. The inspectors determined that the issue was of very low safety significance, because the licensee was still measuring quarterly charging pump flow rates for the testing of the pumps discharge
check valves. The resultant flow rates bounded the requirements of the deleted
TRM Surveillance Requirement. Therefore, the results of the violation were determined to be of very low safety significance and the violation of
10 CFR 50.59 was classified as a
Severity Level IV violation. Because this non-willful violation was non-repetitive, and was captured in the licensees corrective action program, this issue is being treated as a Non-Cited Violation, consistent with the
NRC Enforcement Policy