Title
10 CFR 50.59(c)(2)(ii) requires, in part, that a licensee shall obtain a license amendment prior to implementing a proposed change, test, or experiment if the change, test, or experiment would result in more than a minimal increase in the likelihood of occurrence of a malfunction of a structure, system, or component (
SSC) important to safety previously evaluated in the final safety analysis report (as updated). Title
10 CFR Part 50, Appendix B, Criterion III, Design Control, requires in part, that measures shall be established to assure that applicable regulatory requirements and the design basis, for those structures, systems, and components to which this appendix applies, are correctly translated into specifications, drawings, procedures, and instructions. Contrary to the above, prior to October 12, 2012, the licensee failed to obtain a license amendment prior to implementing a change that resulted in more than a minimal increase in the likelihood of occurrence of a malfunction of a structure, system, or component important to safety and failed to establish measures to assure the design basis of structures, systems, and components were correctly translated into specifications, drawing, procedures, and instructions. Specifically, the licensee identified that a spoils pile created during construction of the water reclamation facility 45 acre reservoir in 2005 was placed in an embankment and obstructed the channel in the East Wash flood plain. This obstruction impacted the East Wash flood plain design requirement to support the site drainage design function of diverting flood waters away from the unit, and would have restricted the flow during a probable maximum flood. The documentation developed to construct the 45 acre reservoir did not adequately evaluate the impact of placing the spoils pile in the East Wash channel. The licensee determined that the
10 CFR 50.59 screening was inadequate and failed to recognize that the obstruction could cause a probable maximum flood to overflow the East Wash channel and potentially impact site flooding due to a probable maximum flood. The licensee implemented corrective actions to remove the spoils pile and conduct training for personnel involved in major water reclamation facility civil projects on performing 50.59 screenings that potentially impact the site. The inspectors concluded that the finding is of very low safety-significance (Green) because the obstruction in the East Wash would not have resulted in an increase in the likelihood or consequence of a probable maximum flood event and has been entered into the licensees corrective action program as CRDRs 3685138 and 4221529. Additionally, the inspectors concluded that the violation of
10 CFR 50.59 is
Severity Level IV because it resulted in a condition evaluated as having very low safety significance (Green) by the
Significance Determination Process.
