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. Specifically, the licensee failed to perform a safety evaluation in accordance with
10 CFR 50.59 for changes made to Section 9.2.7.3.c of the Updated Safety Analysis Report concerning the low-low pressure interlock for the
auxiliary feedwater pumps. The changes made by the licensee adversely affected an Updated Safety Analysis Report-described function in that a previously described automatic feature of the steam inlet valve to the
auxiliary feedwater pump was changed to clarify that this automatic feature was not available under certain conditions
Because the Significance Determination Process 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 changes made to Section 9.2.7.3.c of the USAR, were assessed using the Significance Determination Process
This finding was determined to be more than minor because the inspectors could not determine reasonably that the change would not ultimately require NRC approval. The inspectors determined that this issue was of very low safety significance, because the design basis safety-related function of the
auxiliary feedwater system, to remove reactor decay heat following a loss of normal
feedwater, was not adversely affected, and because the team determined from the
mitigating systems evaluation in the Phase 1 Screening Worksheet that all the questions were answered "No." Therefore, the results of the violation were determined to be of very low safety significance and the violation was classified as a
Severity Level IV Violation. (Section 1R02)
